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Home My WebLink About00-03518 -~ ". "'. _~o _ ~"'-',~': , SHAWN M. GRDJAN PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TARA N. GRDJAN 2000-3518 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 12th day of Jnne ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear befonMelissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenne, Snite 105, Camp Hill, PA 17011 on the 27th day of Jnly ,2000, at 9:15AM 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. FOR THE COURT, By: Isl 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 TillS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . OF T.: i'.. C;I:~f.!~?!1~T(\RY O'.i)"'" On.l I f" ~". (' , elt'.' J !'f'.j "C'r ..., d o' .)10 CUivl;;:Cp "1.'.-' ("r"'UN. iY '-';:" !L,..J 11';../ ...,,'J i I PeNNSYlvANIA j..J5,m &vi ~ ~~ 4!J ~ d> ')5.4:) 'lt~ ~ Z ;11!,' ~.g.{?j) ~~ ~'a4 ~ ~ ._ ~ JW .,.,.. ~ -.J mrl ,,-'"" 1iI!OOI1~m~,"l!i"':YI1"ll!~W!I!;lIIH'lli_~ ,r[w:~IWPl,_ "'III!lit;jf'''':, SHAWN M. GRDJAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- 35/1 CIVIL TERM TARA N. GRDJAN, Defendant CIVIL ACTION - LAW CUSTODY ACTION ORDER OF COURT AND NOW, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before _ . Esquire, the Conciliator, at , 2000, on 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. Either party may bring the children who are the subject of this custody action to the conference, but the children'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, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT THE OFFICE SET CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 240-3166 ~< , ~, "w-;',\&,: SHAWN M. GRDJAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-35/7 CIVIL TERM TARA N. GRDJAN, Defendant CIVIL ACTION - LAW CUSTODY ACTION CUSTODY COMPLAINT TO THE HONORABLE JUDGES OF SAID COURT: 1. The Plaintiff is Shawn M. Grdjan residing at 613 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant is Tara N. Grdjan residing at 214 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Plaintiff seeks joint legal and partial physical custody of the following child: NAME PRESENT RESIDENCE DOB Britney Nicole Grdjan 214 Hummel Avenue Lemoyne, PA 17043 01/29/97 The child was born out of wedlock. The child is presently in the custody of Tara N. Grdjan, who resides at 214 Hummel Avenue, Lemoyne, Pennsylvania. .:iiJlihini!~, During the past three years, the child has resided with the following persons and at the following addresses: Persons Addresses Dates Tara N. Grdjan 214 Hummel Avenue 07/31/99 - present Lemoyne, PA Shawn & Tara Grdjan 613 Hummel Avenue 02/99 07/31/99 Lemoyne, PA Tara N. Grdjan 214 Hummel Avenue 01/29/97 - 02/99 Lemoyne, PA The mother of the child is Tara N. Grdjan who resides at 214 Hummel Avenue, Lemoyne, PA. She is married to Shawn M. Grdjan. The father of the child is Shawn M. Grdjan who resides at 613 Hummel Avenue, Lemoyne, Pennsylvania. He is married to Tara N. Grdjan. 4. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: Name RelationshiD Judy & Ted Grdjan Parents 5. The relationship of Defendant to the child is that of Mother. The Defendant currently resides with the following persons: Name Relationship Britney Nicole Grdjan Daughter Wendy Rumbe1 Mother -,-, -~-~' 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. However, Tara N. Grdjan was granted physical custody of the child in a PFA dated 10/11/99. 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: A. Plaintiff can provide love for his child. B. Plaintiff will place his child's interests before his own. 8. Each known parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting him joint legal custody and partial physical custody. Respectfully submitted, ~'U P. )(j~",- Thomas D. Gould ID # 36508 2 East Main Street Shiremanstown, PA 17011 Phone: (717) 731-1461 ~~ '.--y o l~" '"~,L VERIFICATION I verify that the statements made in the Custody Complaint are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. b- ~- 00 Date ~Jj~ Shawn M. Grdjan , n"'"'' ,( , , SHAWN M. GRDJAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3518 TARA N. GRDJAN, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT ~ AND NOW, this ~; day of the attached Custody Conciliation Summa , 2000, upon consideration of , it is ordered and directed as follows: 1. The parties, Shawn M. Grdjan, and Tara N. Grdjan, shall share legal custody of the minor child, Britney Nicole Grdjan, born January 29, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religious upbringing. Pursuant to the terms of this paragraph, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Father shall have three supervised periods of visitation of two to three hours in duration by July 31,2000. Father is to arrange the location and supervision with Mother's Aunt, Jean Rumbel. 3. Father shall have three unsupervised four-hour visits. Father shall have physical custody from Noon to 4:00 PM on August 5 and 6, 2000, and from 5:00 PM to 8:30 PM on August 9, 2000. 4. To commence Saturday, August 19, 2000, Father shall have partial physical custody from Saturday at 10:00 AM until Sunday at 6;00 PM on alternating weekends for three weekends. Because the parties contemplate that the Father shall have partial physical custody for Labor Day weekend, his weekend for that date shall be extended to allow him to return the minor child until 6:00 PM on September 4, 2000. Father shall have physical custody from after work on Tuesday evenings until 9:00 PM on Wednesday evenings each week. ) .. ~ No. 00-3518 5. To commence September 29, 2000, Father shall have partial physical custody from Friday at 6:00 PM until Sunday at 6:00 PM on alternate weekends. 6. The parties shall alternate holidays. In the event that there is a Monday holiday which should fall on Father's weekend, his period of custody shall be extended until 6:00 PM on that holiday period. The holidays to be alternated shall be Labor Day, Memorial Day and July 4th. For Thanksgiving, Father shall have custody from 4:00 PM on Thanksgiving Day until 6:00 PM on the day after Thanksgiving. 7. During any period of custody or visitation the parties to this Order shall not possess or use any controlled substance, neither shall they consume alcoholic beverages to the point of intoxication. The parties shall likewise ensure, to the extent possible, that other household members andlor house guests comply with this prohibition. 8. The parties shall each have two non-consecutive weeks of summer vacation which shall be scheduled to include their custodial weekend. Vacation plans shall be subject to no less than thirty days' notice to the other party. 9. The parties have agreed to attend counseling focused at improving their skills in communication and coparenting. The parties have agreed to share the copay or unreimbursed costs of this counseling in equal shares. 10. The Father will provide transportation. Mother will assist if the Father is having difficulties with his vehicle. 11. Christmas holiday shall be broken into two segments: Segment A and Segment B. In even numbered years, Mother shall have Segment A and Father shall have Segment B. Segment A shall be from Christmas Eve at Noon until Noon on December 25th. Segment B shall be from December 25th at Noon until December 26th at 6:00 PM. In odd- numbered years, Father shall have Segment A and Mother shall have Segment B. 12. Easter: In the event that Father has physical custody on Easter, he shall have the option of keeping the Child until 6:00 PM. In the event that the Easter holiday falls on Mother's custodial weekend the Father shall have physical custody from Noon until 6:00 PM Easter day. 13. Mother's Day shall be with Mother and Father's Day shall be with Father from 9:30 AM until 6:00 PM. ~ .. ~ - . . . ~"' ~- ~-.,;" . . No. 00-3518 14. The Child's birthday: The parties agree to include each other in the Child's birthday celebration and invite the other party's participation in the event that one parent should decide to have the party for the Child's birthday. BY THE COURT, .J.~ c~ 'i'\ ~_oo ~" f) .,) ( ~~ Dist: Charles E Petrie, Esquire, 3528 Brisban St., Harris urg, P 71 1 Thomas D. Gould, Esquire, 2 E Main Street, Shiremanstown, PA 17011 ..cC,'_ '-''''-~.Uiilllw.~~~~~~;;$l~~~;,ylf{~!'" >- IS) [:=. IT (": ~ ...:::: ~ ("-; =>~ 0",:-- ~-~ .-.)2; 0... ' :<( .~.:J?i ;:....) .:::ij) <'" "1..,- c; 'X:;2' -', ~~H~ 4Ct: ::2' 0 ::::> C) () ""~.p...-"' "~, ~ -"......~ ,. . ~, , """,', ,"'I, .~" , ,,~ vs. AUG 1 8 20~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3518 SHAWN M. GRDJAN, Plaintiff TARA N. GRDJAN, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Britney Nicole Grdjan January 29, 1997 Mother 2. A Custody Conciliation Conference was held on July 24, 2000, with the following individuals in attendance: The Mother, Tara N. Grdjan, and her counsel, Charles E. Petrie, Esquire; the Father, Shawn M. Grdjan, and his counsel, Thomas Gould, Esquire. 3. The parties agreed to an Order in the form as attached with the understanding that a Protection From Abuse Order docketed at 98-3142 Civil Term which Mother is the protected person should be modified to allow for Defendant to have contact with Plaintiff at a designated counseling location for the limited purpose of attending and participating in parental counseling together. rf1J~ ( -!I'M!? Melissa Peel Greevy, Esquire Custody Conciliator "- ~ Date , . 'L.," '.- AUG 1 8 20~ SHAWN M. GRDJAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-3518 TARA N. GRDJAN, Defendant CIVIL ACTION - LAW CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Britney Nicole Grdjan January 29, 1997 Mother 2. A Custody Conciliation Conference was held on July 24, 2000, with the following individuals in attendance: The Mother, Tara N. Grdjan, and her counsel, Charles E. Petrie, Esquire; the Father, Shawn M. Grdjan, and his counsel, Thomas Gould, Esquire. 3. The parties agreed to an Order in the form as attached with the understanding that a Protection From Abuse Order docketed at 98-3142 Civil Term which Mother is the protected person should be modified to allow for Defendant to have contact with Plaintiff at a designated counseling location for the limited purpose of attending and participating in parental counseling together. 1/1b-O,7 Melissa el Greevy, Esquire Custody Conciliator Date