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Home My WebLink About00-02456 ",' . ,', --, -'h,,'~ '1,,,,' '~ "ok: PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff ROBERT C. COYLE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA K. COYLE Defendant NO. 2000 -Jt.t5lp CIVIL TERM IN DIVORCE ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE UNDER SECTION 3301lc) AND 3301(dl OF THE DIVORCE CODE AND NOW, COMES, Defendant. TERESA K. COYLE, and does hereby acknowledge that on the date indicated below she did receive a verified copy of a Comp~;"t ;" D;,o"" filed age;,," he, ;" the ,b<We J: ::tt (J;';t!f" J ERESA K. COYL DATED: II- ~O t{z) [iii~.~IiMWi!I!!.~.m:~'I<ii#ll''l1il:~ffii.'~ii!WJ.i;;!lll~It!tWdi!i'~><Ii~;''';p,~"",,~~C!,~-i 1 ~.......~ ,Ul,L ,,~~, ~_ ~,'~ ,~~~~H ~"r'"',"", .,",:,,,~,c_ >' ,," ,,><c~,'_, ~, ", =. __~ nil""""" ~" ~iilii>~I~' --"~ "l>l!iIl"~ ~"'"'~~' .' . -, o s: 9jljf1 '., <e r.::o ("~ h -0 ~~ t'.) ,-- ~ :2 ~t'flt' - ~""'~ I o -'q - "~I ~; :6 -<: . . ~"" _.~ D'S . -~ IlJ 10DJtP ROBERT C. COYLE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 2000 -c9~IVIL TERM IN DIVORCE TERESA K. COYLE Defendant ORDER OF COURT r) 1-'., AND NOW, this ..<"t.f consideration of the attached Com .respective counsel appear before Conciliator, at W 1;' fl1-t. I on the \ '-\tr\ day of C\\..l.I\....Q... , 2000, at 3~tO -"f2-.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 at the request of either attorney or party, be present at the conference. Failure to appear at the Conference may provide grounds for the entry of a temporary or permanent Order. .2LJ<> 0 FOR THE COURT, By: D/fWft ~<;~, ?s-'l Custody Conciliator ('f,J-- ) 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ~ ."J.~ ~, ,mflUll'J ,~ ~~-~ -.~^'-' - ^ ~'" '- ~", "."",-,,,,,,,,,~,,,-~~,~, ". . u ~. OF ..--".')t)': '~'i'"'l f,I."" L U \,JU f-';\ IJ, . r,t'j C', \',1:" " \,,- ~ ;"',1 ,~ , ,,--,II\\lV "\1 \, t;,--(>;::',i J\>,j'..,~: "~),.J':\ '. \ l CU\~\\.J"'" ': \'-~'I' \ 1/""1'.\:,\1,,\ fli:"I' "'1.:'" ,. f(..\'1I'vl ' 1/;)/;.tJ() &;I.6Jlft' .'~ 7e; 4' ~ 71~ ~ ~ 11" ~/U~~ JT~ 4t'.;ld c.? r' o?b .41 r ~">':~~ I_li,~ ~~~~~""",^",",!,,~~1\"1~'f,'lW'!T'nEr<Mlf~l',~j~"';;~>!!'!''1',~~~~ilflinO!';;!~a;~10'iJ'i'~~;ii;"~'!\ifi~I~~~ .~--~ ,. ';W,"h' ROBERT C. COYLE Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TERESA K. COYLE Defendant NO. 2000- IN DIVORCE CIVIL TERM 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 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, Cumberland County Court House, Carlisle, Pennsylvania. 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, P A 17013 (717) 249-2721 ROBERT C. COYLE Plaintiff Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA K. COYLE Defendant NO. 2000 - ol'lS? CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 33011d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through his attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 504 Mohawk Road, Newville, PA 17241, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 15 E. Big Spring Avenue, Newville, PA 17241, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 39 years and has resided continuously therein for at least six months prior to filing of this Complaint. "";'"-j" 4. Defendant has been a resident of the Commonwealth of Pennsylvania for 35 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on November 19, 1989, in Williamsburg, Virginia. 6. There are (2) two children of the parties under the age of eighteen (18): Courtney A. Coyle Rober! W. Coyle 7-22-90 1-27-92 COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, ROBERT C. COYLE, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II - CUSTODY 13. Plaintiff hereby incorporates by reference averments 1 through 12 of this Complaint as if each averment were setforth fully hereunder. 14. Plaintiff is ROBERT C. COYLE residing at 504 Mohawk Road, Newville, PA 17241, Cumberland County, Pennsylvania. 15. Defendant is TERESA K COYLE residing at 15 E. Big Spring Avenue, Newville, PA 17241, Cumberland County, Pennsylvania. 16. Plaintiff seeks custody of the following children: Name Courtney A Coyle Robert W Coyle Present Res,idence 504 MohawkHoad, Newville 504 Mohawk Road, Newville DOB 7-22-90 1-27-92 17. The children were not born out of wedlock. 18. The children are presently in the custody of the Plaintiff, who resides at, 504 Mohawk Road, Newville, PA 17241, Cumberland County, Pennsylvania. 19. In the last five years the children have resided with the following persons and at the following address: Name Plaintiff Address 504 Mohawk Road, Newville Dates present to 1997 Plaintiff & Defendant 504 Mohawk Road, Newville 1997 to 1995 -.!l!e, 20. The Plaintiff, the father of the children, is residing at 504 Mohawk Road, Newville, PA, 17241, Cumberland County, Pennsylvania. He is married. 21. The Plaintiff currently resides with the following persons: Name Courtney A. Coyle Robert W. Coyle Bryon P. Keck RelationshiD Daughter Son Step-son 22. The Defendant, the mother of the children, is residing at 15 E. Big Spring Avenue, Newville, PA 17241, Cumberland County, Pennsylvania. She is married. 23. The Defendant currently resides with the following persons: Name Unknown RelationshiD 24. 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. The court, term and number, and its relationship to this action is: 25. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. The court, term and number, and its relationship to this action is: 26. 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 right with respect to the child. The name and address of such person is: 27. The best interest and permanent welfare of the child will be served by granting the relief requested because (set forth facts showing that the granting of the relief requested will be in the best interest and permanent welfare of the child): ,~~~ "~'I 28. 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. All other persons named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim WHEREFORE, Plaintiff requests this Honorable Court to order that the parties: Respectfully submitted, ~ 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 - Date: '-I J 11 J 00 - ,'. , . PETER J. RUSSO, ESQUIRE PA Supreme Court 10: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff ROBERT C. COYLE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW TERESA K. COYLE Defendant NO. 2000- IN DIVORCE CIVIL TERM VERIFICATION I, ROBERT C. COYLE, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsificatiorl to authorities. ~(~ ROBERT C. COYL . 1.1_ pJOCl Date: l :i:iit~'';'~I''''r.liiiilii~~-ll!liI!!Wili:!~~'W-:!&lHMi''It~~~~~i<J,'\M[~j~~~II~ilO - ~:_f ,,-~< ,'.,.", "_~ A.., _, ." ..~~ ~ ~~ '. ,~ ' _.., t , :A) ~ ~?::::- -Q)~ -I::: ur ~ Q UJ lU. '.... 'th .. ""C<''''~', .. " " ,.. :,.'" ~~ &'=> g~ ~ ~ ~ f - ~ -~,,, ~,"~ ~ " "~ ""~.-~ o c z 2~C g -.j.. ~~ Q ~ ii:' O~ ~ ~ ~~ ~ '- ;:t;c:' s.~C~J o _0 " " > _" ~ , , L'-: =< = ~', , . . Cl C"') :C'!"t --::J ::0 o .'""1 1J tD .::J ,c') :;::-;;r. , j::~f~ ~~:~ :.0 -< :...n r.) , .~ ~.,~ ~ FRANCIS X. O'BRIEN, JR., on behalf of himself and Brennen X. O'Brien, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW :IN PROTECTION FROM ABUSE JAMIE L. DANZBERGER, Defendant :NO. 00-2457 CIVIL TERM ORDER AND NOW, this ;:;!h ~y of April, 2000, the Plaintiffs attached motion for continuance is granted. The Temporary Order entered on April 19, 2000, shall remain in effect and the hearing on this matter shall be held on this i; ~ay Of~, 2000. J I: 30 ~ Ih- ,0" ~3, Copies ofthis Order shall be sent to the same persons and offices which received the Order of April19, 2000.. '+~2Ii --fro -P~ ~LC-0td ~t 1..\ 'f ~JU5 ~~. ./l ~ 'iRk I.U"~ 0ltJftuJ:- fJPA- ~~1iU ~ ~Jtv>>- W-M' 4-~~~-o-o . ~ , ,,- "'^' :'1 flrr~ A.. (b p;--;; , " ~,~ , '.~ ,,~ . ""11'1'1'" C! i~ ,"'. :~':--' i .i 11 '1\ I t V,lliL:J~' '......"..., . ....1-'1"',\/[11,');11' 1..Ir:\\:i\~:JI }//\!\i!;'\ " -"" ~_I ,IJ -~~~-,," - """",_~=""",\qi"""'1.~,~~~~_.H'l~Qtmf'""1!T~"!I, ",~,,!!lIl!M'~ ,""',~, .~ , ~ . ri"ol".:.c . FRANCIS X. O'BRIEN, JR., on behalf of himself and Brennen X. O'Brien, Plaintiff :IN TIffi COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW :IN PROTECTION FROM ABUSE JAMIE L. DANZBERGER, Defendant :NO. 00-2457 CIVIL TERM MOTION FOR CONTINUANCE The Plaintiff, by his student attorney, at the Family Law Clinic, respectfully represents that: I. On April 19, 2000, Plaintiff filed this action and the Court entered an order granting Protection from Abuse and various other elements of temporary relief and set a hearing for April 26. 2000, at 3pm. 2. As of April 26, 2000; the defendant has not been served by the Sheriff s office. 3. The Plaintiff has had no contact ,vith the Defendant since the filing of this action. WHEREFORE, Plaintiff prays that the court will continue the Temporary Order pending scheduling of another hearing. Date: !i/1t/f12- ~^,J.- Donald Marritz, Staff Attorney Thomas M. Place, Supervising Attorney Robert E. Rains, Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 Counsel for Plaintiff tf""~ ""'.. c. !lii[jt\il;J(l!l!'~""< ~-'.llmJ~lt-ill~Wli;.~~,,,,,~,,,,_;~~~_''"'"''''"''~._''''''"' CJ ~; -C'c Uir ;ff-:;~; Fl!~'~ ~-, 1"~~ ~(~~ ~ :(,1 "",,>_~, -,0-,,' '~" ~ _~ -- - ~','~, ,~ -~," 0"--- ~ . ,~,:::) o .~ '-j ~c"> ----.., ~: ~} r,~) c~ ~:'G ~;.,. :;-? ~,--J 5~ =D -< ~D . -" '","" . ROBERT C. COYLE, P:j.aintiff . . IN THE CCURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : vs. : NO. 00-2456 CIVIL TERM . . TERESA K. COYLE, Defendant . . CIVIL ACTION - LAW IN CUSTODY . . OODER OF CClJRT AND roq, this ;)1J11. day of ~ ~ consideration of the attached Custody C nciliation and directed as follows: , 2000, upon Report, it is ordered 1. The Father, Robert C. Coyle, and the Mother Teresa K. Coyle, shall have shared legal custody of Bryon Keck, born December 22, 1983, Courtney A. Coyle, born July 22, 1990, and Robert W. Coyle, born January 27, 1992. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. During the summer school break, the parties shall have custody of the Children in accordance with the following schedule: A. The parties shall alternate having custody of Courtney on a weekly basis beginning with the Mother having custody on Monday, June 19, 2000 at 5:00 p.m. Thereafter, beginning Friday, June 30, 2000, the Mother shall receive custody of Courtney on alternating Fridays at 5:00 p.m. for her alternating weekly periods of custody. The Father shall have custody of Courtney during the interim alternating weeks. B. The Father shall have primary physical custody of Robert. The Mother shall have custody of Robert on alternating weekends from Friday at 5:00 p.m. through Sunday at 5:00 p.m., beginning Friday, June 30, 2000. The alternating weekend schedule shall coincide with the weekly exchanges of custody for Courtney so that the Children are together every weekend. c. The Mother shall also have custody of Robert for 2 non-consecutive weeks to be scheduled on the same weeks in which the Mother has custody of Courtney. The specific times and dates for the 2 one week periods of custody under this provision shall be arranged by agreement of the parties. D. The Father shall have primary custody of Bryon and the . . '. Mother shall have periods of partial custody as arranged by agreement. 3. The parties shall share or alternate having custody of the Children on holidays as follows: A. cmu:STMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 8:00 a.m., and Segment B, which shall run from Christmas Day at 8:00 a.m. through December 26 at 12:00 noon. The Mother shall have custody of the Children in every year during Segment A and the Father shall have custody of the Children in every year during Segment B. B. ALTERNATING HOLIDAYS: The parties shall alternate having custody of the Children on the following holidays with the specific arrangements to be coordinated with the Mother I s work schedule and the Father's plans: Thanksgiving, New Years, Memorial Day, July 4th and Labor Day. C. MCJ.rHER'S DAY/FATHER'S DAY: The Mother shall have custody of the Children every year on Mother's Day and the Father shall have custody of the Children every year on Father's Day, with the specific arrangements to be made by agreement of the parties. D. The holiday custody schedule shall supersede and take precedence over the regular custody schedule. 4. The parties shall share the responsibility for transporting the Children for exchanges of custody as arranged by agreement. 5. The parties and counsel shall attend an additional Custody Conciliation Conference in the office of the Conciliator, Dawn S. Sunday, Esquire, on August 30, 2000, at 9:30 a.m. for the purpose of discussing custody arrangements for the school year. Pending further Order of Court or agreement of the parties, the parties agree that Courtney shall remain enrolled in her current elementary school. 6. This Order is entered pursuant to an agreement of the parties at a custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. J. . f\~ C ~ 1\1,00 l/.r \Z ~~ cc: Peter J. Russo, Esquire - Counsel for Father Jason Kutulakis, Esquire - Counsel for Mother "', .< ,""~,' ~ '"""""'~"""" FILEO'{)FFICE 0."" 1,'../1: OCon.;'('~iO"'Ai"y , , ',", I" ",\./1'./ 1M DO JUN 2 7 AN 10: 46 CUMf3j;RI.NVD COUNTY PENNSYLVANIA !l nPJI , .~_ ll1'1Blifi~ffl!i!I!Itl~1 ~Jt^'i!iltt'\!l'fl!'M',lml -",.,~~"~ ' 11II ,~,J~ -~""'I ""~. , ..;,~ w: ROBERT C. COYLE, . IN THE COURT OF COMMON PLEAS OF . plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-2456 CIVIL TERM . . TERESA K. COYLE, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CUSTODY CCIIlCILIATICN SIJMMARY REPOOT IN ACCDIDANCE WITH CUMBERLAND CJOON'l'Y RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned CUstody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bryon Keck Courtney A. Coyle Robert W. Coyle December 22, 1983 July 22, 1990 January 27, 1997 Father Father Father 2. A Conciliation Conference was held on June 14, 2000, with the following individuals in attendance: The Father, Robert C. Coyle, with his counsel, Peter J. Russo, Esquire, and the Mother, Teresa K. Coyle, with her counsel, Jason Kutulakis, Esquire. ~ 1'1/ doOV Date 3. The parties agreed to entry of an Order in the form as attached. Dawn4~c;h CUstody Conciliator '......:i.i" ~~ -,--,''''' , , J~ o :ar- , ~~<' 'tJ V , 1), ". , \" '. , PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff ROBERT C. COYLE Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. TERESA K. COYLE Defendant NO. 2000 - 2456 IN DIVORCE CIVIL TERM PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, ROBERT C. COYLE, and certifies that on 4-19-00 , he did serve the Defendant, TERESA K. COYLE with a true and correct copy of the Divorce Complaint filed against her alleging the parties' marriage was irretrievably broken under Section 3301(d) and Section 3301 (c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to TERESA K. COYLE at 15 E. Big Spring Avenue, Newville, PA 17241, Cumberland County, Pennsylvania. [ ] Service of Plaintiffs Complaint on the Defendant, TERESA K. COYLE was effected on April 20. 2000 . A true and correct copy of the U.S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. [ ] Service of Plaintiffs Complaint on the Defendant, TERESA K. COYLE was effected on April 20. 2000 . A true and correct copy of Defendant's Acknowledgment of Service is attached hereto and the original is affixed to this document. ~- Peter J. Russo Date: Julv 19. 2000 ~~ .~ ... I also wish to receive the following services (for an extra tee): 1. 0 Addresse.'s Address 2. 0 Restricted Delivery Consult postmester for fee. 4a. z.1"Jf:mber 4b. Service Type o Registered o Express Mail 0 Insured o Retum Receipt for Merchandise 0 COD 7. Date of Delivery - ... " " 'iij ~ ,~ .l!! ." != .j "c, 'S :g m 'm 'w :c ,0 .e( SEN ER: -Complete items 1 and/or 2 tot additional services. -Complete items 3, 4a, and 4b. -Print your name and address on the reverse of this fonn so that we can return this card to you. - Attach this fenn to the front of the mailpiece. or on the back jf space does not pennit. -Wrile.Relum Receipt Requested" on the maiJpiece below the article number. -The'1'llfUm Receipt will show to whom the article was delivered and the date delivered. ~~~~,roCo~I-t 15[, B,~ Spr:Y1j PtvmlK NfW/, ILL P fT-11 ?-'-l/ ,. ~ertified fC-~-zZ> 8. Address.e's Address (Only If requested and fe. is paid) Domestic Return Receipt ~'--> !:I 1'\ i I i . . I 'I ;'1 :' :1 " :1 ii !'I II , \1 " " ii '" li 1,1 ),1 :1 :i Ii I e il " m C, II 'ii u f' " II: !I E ::l I'] D II: II '" I c 'iij :\ ::l ~ .e I, ::l :i 0' i '" .l< II c .. Ii .c ... ~ i_~jj~;'~W_~~~~~!Q!IWlii.l~jjjilWii' ok" :,~- ~:;", ~J,lJ[!i ,__"~,.>,~,_ "'~"_~""_"'J)r;f ,''-;-_'' ", " ^, ,0 ~",.~, -"1 }C:",_ ,,,,,,",~ C_",,- ~. oIiiU.C.,.c""""","," L.::J] z- ,,~ (J)> C) ~Z 0 ~ v :e:O _.~'. ""-0 5>C N L- c:- -? --. 0) ,~- .m .. ... ~~ , "-'- . -~-" ' ... ... . ROBER'l' C. COYLE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 00-2456 CIVIL TERM : TERESA K. COYLE, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . CJIDER OF COURT AND ~, this ~A consideration of the attached and directed as follows: day of ~ Custody Concihation Report, , 2000, upon it is ordered 1. The parties shall submit themselves and their minor Children to a custody evaluation to be performed by a prOfessional selected by agreement of the parties and counsel. The purpose of the evaluation shall be to obtain independent prOfessional recommendations concerning ongoing custody arrangements which will best serve the interests of the Children. The parties shall sign any authorizations deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or the Child~en. The parties shall equally share all costs of the evaluation. 2. Pending further Order of Court or agreement of the parties, the prior Order of this Court dated June 27, 2000 shall continue in effect as modified by this Order. 3. In the event the Father takes all or any of the Children to FloriGa over the Christmas holiday as planned frcxn December 23, 2000 through December 28, 2000, the Mother shall have custody of the Children for the remainder of the Children's Christmas school break as permitted by her work schedule and in 2001, the Mother shall have custody of the Chilfdren frcxn December 23 through December 28 to compensate for the loss of the holiday period in 2000. 4. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. j~ r _~ DD L<< '\/\~ cc: Peter J. Russo, Esquire - Counsel for Father Jason T. Kutulakis, Esquire - Counsel for Mother ~ .. ",- ,0,", " ,"_-"" """ ~ ' ~,- ~ , 0'-"". J!'I!ll!!Il!lfi".I'IIiIl!I!!I!t ~_, .. ..'. , ~, - '~ '_' ,-~"j~C.'" ,"_' ,__ *~, ,~~" ~~,""-_' -, "'T'""".' -~'I,\,li )1/HY on STT' .- 7 /J,! j'n. ')r, l".11 t,' {, CUM',~~,;i~;~'< \ju C>JUii7Y PtNNSYLVANiA " _.--- ..".",'""'~, ~"mlfWffiW.~ll'F!l\'-f1i!f!i~jI;jI!ft!~~Q;i~IiI~jj!@~!!i'~mM ,oc" P"f''''''''''''Jll1W!lIfllV Ii!l>- ~ , .,. ROBERT C. COYLE, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 00-2456 CIVIL TERM . : TERESA K. COYLE, . CIVIL ACTION - LAW . Defendant . IN CUSTODY . PRIm JUDGE: Edward E. Guido CUSTODY CXl!iICILIATIOO SUMMARY RmET IN ACCXRDANCE WITH <DIBERtAND <XlUN'.l'Y RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Bryon Keck Courtney A. Coyle Robert W. Coyle December 23, 1983 July 22, 1990 January 27, 1992 Father Mother/Father Father 2. A Conciliation Conference was held on August 30, 2000, with the following individuals in attendance: The Father's counsel, Peter J. Russo, Esquire, and the Mother, Teresa K. Coyle, with her counsel, Jason T. Kutulakis, Esquire. The Father, Robert C. Coyle, participated during the Conference by telephone and appeared at the Conciliator's office at the end of the Conference. 3. The parties agreed to entry of an Order in the form as attached. fh;~ l3 j , aoOtJ Date ' J2.- ~--&1 Dawn S. sunday, Esquire Custody Conciliator