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HomeMy WebLinkAbout00-04683 MATTHEW G. GIBSON IN 1HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF V. MELISSA C. LOPEZ 00-4683 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 6TH day of JULY ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39WestMaiuStreet,Mechauicsbufl~,PA 17055 on the 31ST day of AUGUST, 2000, at 1:00 PM 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 Dawn S. Sunday. Esqtf Custody Conciliator 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 FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 , . . . , , ....---' *~ 'd..... '~~~:ililiI~~aJi~mm~iiftffiEW~,d~oGl!itii!(;\j~&rii[:m .. ii, ~,'" " ~, "~b~' ~ ~iII8IIIilliI~llIIIiiIlillii'- OF T: _, ,,".q~c':'FICE" _F\!._rr)_, "--;!\'LfAHY 00 Ju"l -_ </' ~ , PN 2: 07 CU},'IY<, wPEN'tf3VgA~~UN7Y )-?'a?M-~~ '~'4~ ~;~ :::::::% 7fc~;:f~ ~'" ~,. ~ ~~_. ~,_~ o. _ _"','~'v.~'-" ""~ 'd' ,. " MATTHEW G. GIBSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. dCX:xJ-LJ.<.o.'6'3 Cl v; I : IN CUSTODY MELISSA C. LOPEZ, Defendant ORDER OF COURT AND NOW, this day of ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the day of , 2000, 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. FOR THE COURT, By: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 --, ,~ ,. ~< .- ":".."c",,,;.,,,,_"_ __.__~_ ..~ ,._ ., ~",,,__,~_,~,_ ~ "i--7' ~ ~""",,,.,,.,_ -' c__. '_. ",_-,~-"'___~~_~_~_~_," ' ~"~~.",__-_"=-.-""o,_",, .-~#~w > . . n- . MATTHEW G. GIBSON, Plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIlL ACTION - LAW : NO. tJ1J - l.f & f.3 e.wu -rR..t..v- MELISSA C. LOPEZ, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, MATTHEW G. GIBSON, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is MATTHEW G. GIBSON, residing at 3 Plainview Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is MELISSA C. LOPEZ, residing at 103 Umberto Street, New Cumberland, Pennsylvania 17070. 3. The Plaintiffis seekingjoint legal and physical custody of the following child: Name Residence Age 16 months Kaylee Drew Lopez 103 Umberto Street New Cumberland, PA 17070 The child was born out of wedlock. The child is presently in the custody of Defendant, MELISSA C. LOPEZ, who currently resides at 103 Umberto Street, New Cumberland, Pennsylvania 17070. Since birth, the child has resided with the following persons and at the following addresses: (a) From birth through 6/8/2000 2 Marshall Drive, Apt. 5-K, Camp Hill, PA 17011 With Defendant, Melissa C. Lopez, and maternal grandmother i 7_ .'" ~_ '0' ,'_-'C',"" .-c~_""",,~, ~,,_,~ _c." _,,",_~_ ,.. ,'Eo""'" "_'_"_'__'''~J''\",n~ _, . _~''',!,,~_, . _, ' ^~ _ "_'." ,0' . .'~r___ _ (b) From 6/8/2000 through the present 103 Umberto Street, New Cumberland, P A 17070 With Defendant, Melissa C. Lopez, and Defendant's boyfriend, Jason Stoner The father of the child is Plaintiff, MATTHEW G. GIBSON, residing at 3 Plainview Road, Camp Hill, Cumberland County, Pennsylvania 17011. He is presently unmarried and residing with his parents, Philip G. and Barbara A. Gibson. The mother of the child is Defendant, MELISSA C. LOPEZ, residing at 103 Umberto Street, New Cumberland, Pennsylvania 17070. She is presently unmarried, but is residing with a boyfriend named Jason Stoner. 4. The relationship of Plaintiff, MATTHEW G. GIBSON, to the child is that of natural father. 5. The relationship of Defendant, MELISSA C. LOPEZ, to the child is that of natural mother. 6. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said child pending in a court of this Commonwealth or any other state. 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 2 :1,., -, - '---,:<X~~'- _F,.":"'~_ ,,'-0/,,,"", ",,~-_~__.' 'f, __ ~,'__ --,- ~~--,---",--~"~--"-----'--~'- ,.---,- ,- '~'~"'~"-"-'''-'~'-' ~~ p -'""-',~ ~, , ~ """."- 7. The relief requested by Plaintiff is in the best interests of the child because it is crucial for her to have a strong relationship with both of her parents. Further, the Plaintiff and his extended family have been actively involved with the minor child since birth and have exercised a substantial amount of physical custody ofthe said child until June 8, 2000. Since that date, when the Defendant commenced residing with a new boyfriend, she has severely restricted Plaintiffs access to or partial custody of the minor child. 8. Each parent whose parental rights of 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 entry of an Order of Court granting him joint legal and physical custody of the said minor child. Respectfully submitted, DATED: toIL7ft> ~~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court LD. #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff 3 ,~," , VERIFICATION I verify that the statements made in the foregoing Complaint for Custody are I I I il _ I II " II I I true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATED: t/Lfoo I/Idlu ,)4;. .~~ MATTHEW G. GIBSON, Plaintiff 0' ,"_" '-;'-e''''.'-,c''' ,",~":,_"..,-",,,.,~ ,___c__c-,~"q,_~---':1' _'-"'_ ,_,_,__,__" .'" "r,_ ___~_,~.'~ "0'__ - --," -~ ',~-, - - -'''~'- -, I' " _ ^,' "",,,q' \"-- - " ... MATTHEW G. GIBSON, Plaintiff I : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIJL ACTION - LAW : NO. 2000-4683 MELISSA C. LOPEZ, Defendant : IN CUSTODY CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that: 1. On June 30, 2000, a Complaint for Custody was filed on behalf of Plaintiff and against Defendant in the above matter. 2. On June 30, 2000, I forwarded, both by ordinary first class mail and by certified mail, return receipt requested, restricted delivery, a true and correct copy of the Complaint for Custody, to Defendant, MELISSA C. LOPEZ, addressed to 103 Umberto Street, New Cumberland, Pennsylvania 17070, as evidenced by the sender's receipt attached hereto. 3. The aforesaid certified copy of the Complaint for Custody sent to the Defendant, MELISSA C. LOPEZ, was delivered on July 7, 2000, as evidenced by the return receipt card signed by the Defendant and attached hereto. H ",,, ." -'. -~-~ "'-'"'i," ",,', - , ".-'-.,,;, -.-",y., - '.-li'.', C", -.' v.' _,_,__).___~'"",,,,,,,~, _ -1.7. ,-_' ,_, .. -~ ~ ,-"^ , ~" -~. ,-- 4. To the best of my information and belief, the signature on Part C of the return receipt card is, in fact, the signature ofthe Defendant, MELISSA C. LOPEZ. DATED: 71/1(OD d;J!i CONSTANCE P. BRUNT, ESQUIRE Supreme Court J.D. #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 Attorney for Plaintiff 2 !::""" ",- ,." -~ ",-,", '",,-- - .- '.''"'''''''l 'c:'''''-_'~ ,~-- ,- '"".=,'" _ """""'1"-" .<,' 'r"~''f'''''~--'' ~ '"-,r.,_,." 2 . "'~.,__,"_'_"~"_ > CO, _,' _. _d_ G ; klSD[V _ Z 093 -529 858 US Postal Service ._ Receipt for Certified Mail No Insurance Coverage Provided. on '" '" ~ Do not use for InternatIonal Mail (See reveme) Sent 10 . M';lissa c. Looez Stre(lt & Number 103 Umberto Street Po~Offlce,_Stare, & ZI~C6de 17070 New land PA Postage $ .55 - Certffied Fee . 1.40 - -- Special Delivery Fee Restricted Delivery Fee 2.75 Return Receipt Showing to 1.25 Whom & Date Delivered Retum Receit ShowingTo Vm:xn, Date. & Addressee's Address TOTAL -postage & Fees 55 $ 5.95 Postmark or Date June 30, 2000 -- ." 0- "" ci o to "" E (; u- rn 0.. .' . _ Complete items 1, 2, and 3. Also complete .. -" item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the carel. to you. __ . Attach this card to the back of the maiJpiece. or on the front if space permits. 1. Article Addressed to: . _,-- ~ Melissa C. Lopez '. 103 Umberto St~et~ New CumberlandV""Pl\:. 17070 ,. I ~~nature X;r.,..,;.~ 0, o Agent D Addressee DYes D No ._2 3. Service Type W' Certified Mail o Registered o Insured Mail o Express Mail o Return ReceIpt for Merchandise DC.D.D 4. eS~r1cedOerrv~r __.DIlYes...... 2. Article Number (Copy from service label) Z 093 529 858 _~S Form 3811 , July -19~99 Domestic Return Receipt 102.595'GG-M-1789 -~ - -- SfP 5 2000 MAATTHEWG. GIBSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA .' : vs. . NO. 00-4683 CIVIL TERM . . . . CIVIL ACrrON - LAW . MELISSA C. LOPEZ, : Defendant : IN CUSTODY OODER OF (XJ(JRT AND NOW, this 31st day of August, 2000, the Conciliator, having determined at the conciliation Conference that the parties were able to reach an agreement as to all outstanding custody issues as provided in a written custody proposal drafted by counsel, hereby relinquishes jurisdiction in this case. Counsel for the parties agree to submit the custody proposal and proposed order directly to the Court for entry of an order. FOR THE COURT, Daf!:~~ Custody Conciliator ;'~ c. ,'. , ( - > _._~," , , ~~- IJ!~_ ('<") C 7- '3~ ,)~ (.:i ::s '---""-- ~jp CCZ i; ilL! 'J:[L " ~':J u co 'lr" ',"'C: ~:r') I (:.... L-...; (1': "-. .:=) """""'. .=-~ Ijl. W~ ..","- .. "' "JU'!\l~~~~~"V.J.~~;;>-:;-~~~~~""l Ii'\'C: ~._~" .. MATTHEW G. GIBSON PLAINTIFF V. MELISSA C. LOPEZ DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-4683 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, this 4th day of December, 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Dawn S. Snnday, Esq. , the conciliator, at 39 West Main Street, Mechanicsbnr2, PA 17055 on the 21st day of December, 2000 , at 1:00 p.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 defme 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: /sl Dawn S. Sunday. ES~ Custody Conciliator The COUli 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 HA VB 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 " I' I ! I I I I I :"h;""'~ -"~ _' , , .' ~- 'illilI~~""""",""OI;;o~iIIrI~lillIIMj~~lti!ititQ!ii;i"~<iI,;t$1illC~,I}~","",,,~~;;w,!.~IJi~""""""""' ilitd tlP' ~ --~ -L M.-J ~':i ~"-'-'~ !d-tj.tJtJ /rX-C/rcZ? /;( - If- tJCJ -,' ' .<-~-- FiLE!YOFFlce N"' 1'. .,- -.c.""','" 'ONOT""Y ur .r\t. :-.',,_,i[1; It\n 00 lJEC -4 PM 3: 30 CUMBERLA"lD COUNTY PENNSYLVANIA dd-.~~~,~4~ ~ ~ b 4- ~ qt:-~ ~~~ ~4~ ~~ ~"' __ _'n .,~ ','__,'> ~__, ___ ~,. _.. __ ___ ,_ ,_ _~_. . . -- -- MATTHEW G. GmSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIJL ACTION - LAW : NO. 2000-4683 MELISSA C. LOPEZ, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this day of , 2000, upon consideration ofthe attached Complaint For Custody, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at day of , 2000, at _ .m., for a Pre-Hearing Custody Conference. At on the 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: 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 - -""(',.',, -~-. "'c""~"',r_,,_ "_'~_"'''" .;>"). ~ ,Co ,,_ ~ ,~ "'_""~ .~, '''''YI-?' ,..,,,,,7_",y~"_ ,"" '_-___~_"', _~_,"-_ ,'__ _ 0 '."_'~." __ . . ,__ _"0'"" 'oN .-' _ .."., ,,_.., . .<. '. -,. ,,' -- ,~-- MATTHEW G. GmSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLANDCOUNT~PENNSYLVAMA v. : CIVIJL ACTION - LAW : NO. 2000-4683 MELISSA C. LOPEZ, Defendant : IN CUSTODY AMENDED COMPLAINT FOR CUSTODY AND NOW, comes the Plaintiff, MATTHEW G. GIBSON, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and respectfully represents as follows: 1. The Plaintiff is MATTHEW G. GIBSON, residing at 3 Plainview Road, Camp Hill, Cumberland County, Pennsylvania 170 II. 2. The Defendant is MELISSA C. LOPEZ, residing at 2 Marshall Drive, Apt. 5- K, Camp Hill, Pennsylvania 170 II. 3. The Plaintiff is seeking joint legal and partial physical custody of the following child: Name Residence Age Kaylee Drew Lopez 2 Marshall Drive, Apt. 5-K 22 months Camp Hill, Pennsylvania 17011 The child was born out of wedlock. " , o,~ ;,_c-,,,.,.~__,,_,-,_,,-__~__!" ,,'et.' ",'!~"'-""'~'" 'C'"' .,,,_,,,, --''''''-""',''','__''"'"1".-_ ,,~,,-.'-A-' -"co _'__~,_,_, 'c' ,,'r. 'Y""";"F~ -'of" ____~__~ .'. ,,]'.c,,,,e,,,,",,__,_.' ", " ' -~- . . The child is presently in the custody of Defendant, MELISSA C. LOPEZ, who currently resides at 2 Marshall Drive, Apt. 5-K, Camp Hill, Pennsylvania 17011. Since birth, the child has resided with the following persons and at the following addresses: (a) From birth through 6/8/2000 2 Marshall Drive, Apt. 5- K, Camp Hill, P A 17011 With Defendant, Melissa C. Lopez, and maternal grandmother (b) From 6/8/2000 through mid-August, 2000 103 Umberto Street, New Cumberland, P A 17070 With Defendant, Melissa C. Lopez, and Defendant's boyfriend, Jason Stoner (c) From mid-August, 2000 to the present 2 Marshall Drive, Apt. 5-K, Camp Hill, P A 17011 With Defendant, Melissa C. Lopez, and maternal grandmother The father of the child is Plaintiff, MATTHEW G. GIBSON, residing at 3 Plainview Road, Camp Hill, Cumberland County, Pennsylvania 17011. He is presently unmarried and residing with his parents, Philip G. and Barbara A. Gibson. The mother of the child is Defendant, MELISSA C. LOPEZ, residing at 2 Marshall Drive, Apt. 5-K, Camp Hill, Pennsylvania 17011. She is presently unmarried. 4. The relationship of Plaintiff, MATTHEW G. GIBSON, to the child is that of natural father. 5. The relationship of Defendant, MELISSA C. LOPEZ, to the child is that of 2 ~^,'-, ,'i=-;"1"I'-<.",r,i.,"'--'" "___"""',..;_ ~ "'.,d' - __",___,~",. ''''>'''''':,,_,~, _. "_"._~_"_~"" ,._' ,_ " .'.''''-- ",~-- ,~"-,,,,~, ., ,. ,,~'~ ,-- natural mother. 6. Except as set forth hereinafter, the Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the child in this or any other court. Except as set forth hereinafter, the Plaintiff has no information of a custody proceeding concerning the custody of the said child pending in a court of this Commonwealth or any other state. 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 relief requested by Plaintiff is in the best interests of the child because it is crucial for her to have a strong relationship with both of her parents. Further, the Plaintiff and his extended family have been actively involved with the minor child since birth and have exercised a substantial amount of physical custody of the said child. On June 30, 2000, the Plaintiff filed a Complaint For Custody in the above-captioned matter, seeking the entry of an Order granting himjoint legal and physical custody of the said minor child. The parties appeared for a pre-hearing custody conference before Dawn S. Sunday, Esquire, Custody Conciliator, on August 31, 2000, at which time they entered into a tentative agreement for resolution of the 3 Ii .,.. . ;'y,-_-__.-,-_'",~~_~_~ -,~-.,,;, ~---~ ,-;>" ".-,,'" ","",;,,,", -.;_~~'_'5',~"",., .,"'-L- .c',,, _ --c,;'"'f!'~o"._n""__,_." _~ ,. ~ _',' _ , "", ''C' _~,' _ _~__, _,_'O.".oo~" nO< ~,O"__ ,-..' _, _ , _" . ~, " custody issues relating to their daughter. Since the pre-hearing custody conference, however, the parties have.been unable to reduce their tentative agreement to writing for submission to the Court as a proposed Order of Court. Plaintiff therefore requests the scheduling of a second pre- hearing custody conference with the Custody Conciliator, and a hearing thereafter before the Court if necessary, to resolve the issues of custody of the minor child. 8. Each parent whose parental rights of the child have not been terminated and the person who has partial physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the entry of an Order of Court granting him joint legal and physical custody of the said minor child. Respectfully submitted, DATED: If ILL/CO M CONSTANCE P. BRUNT, ESQUIRE Supreme Court LD. #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff 4 :"' ".0 ;,,,,,"'_"~ ,"'"~~,,,.,.,~. .,,",,,_.','< ,'_',,,:- ,""r~-~_',_~., ,~_~___ '_J,_ '~"_'_"""_.' ;,' .,., --"-c.,,,'" d '.'< ,'-""'.Y., ,-,~ ,_,~ .,~, _.. ~,__ ",,~ ",,""',_,"".~ '. ,_ ., ,,.~___ VERIFICATION I verify that the statements made in the foregoing Amended Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATED: Illti-let) ~~~JI4~- MATTHEW G. GIBSON, Plaintiff I,. ., - ,'. -"~'_~~-" c'"'.: "~ ,: ': -" ,":" ".",_", i\' 0' '-"'''''., '!'., _,<C-o ."'_"_ -~,__, ~. """ ~_""~', " _ ,"_~'_; ".. ~, _~'.. . 0' ~~,'_ ~ __ _... ~ ,~._ ~ ,~~_ ~. , ,", --"~ , _._"'~ ~ . - CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the )~..M day of N6~ ,2000, I served a true and correct copy of the foregoing Amended Complaint For Custody by depositing same in the United States Mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Melissa C. Lopez 2 Marshall Drive, Apt. 5-K CampHill,PA 17011 Defendant Samuel L. Andes, Esquire 525 North Twelfth Street Lemoyne, P A 17043 Attorney for Defendant ~~ CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff ,- . - ",'., _' '''~',;;r;'", ,",. to'", -.C",~." _~_ .<" ~ ,~~",~"':>'--' '-" '~", -"'.- ',' ",",,",~ -""""., " "___.,,,",_~ ,--, ,. "~_ "" ,_ ',^,',-" ~'~", "._=,_> ' .~. _~ , ',' ~<" _. _, _", "H" ~ ,,_O~. ,,_. ~'.' MATTHEW G. GIBSON, plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 2000-4683 CIVIL TERM . . MELISSA C. LOPEZ, : CIVIL ACTION - LAW : CUSTODY Defendant ORDER OF COURT AND roi, this 'Yl. consideration of the attached and directed as follows: day of Qp~tJ..- Custody ConC1 '1ation Report, , 2000, upon it is ordered 1. The Father, Matthew G. Gibson, and the Mother, Melissa C. Lopez, shall have shared legal custody of Kay1ee Drew Lopez, born January 31, 1999. All major decisions affecting the growth and development of the Child, including but not limited to medical and dental treatment, counseling dr similar treatment, education, athletic pursuits and extrac~iCUlar activities, and religious training, shall be made by the parties jointly, after discussion and consultation with each other and with the intention towards obtaining and following a harmonious policy in the best interests of the Child. Each party agrees to keep the other fully informed of any event or activity that could reasonably be expected to be of significant concern to the other party and will keep the other party fully informed of the progress of the Child's education and social adjustments. Each party shall be entitled to complete and full information fran any doctor, dentist, counselor or mental health professional, teacher, school authority or other person or entity of any nature having any information with regard to the minor Child, and each shall be entitled to receive copies of any reports given to either of them as a parent of the minor Child by any third party or entity. When the minor Child commences school or pre-school attendance, both parties' names shall be listed with the school as the persons to be contacted in the event of an emergency and to be notified regarding school events or other issues relating to the Child. Notwithstanding the foregoing, it shall be the primary responsibility of the primary physical custodian to provide the non-custodial parent with copies of report cards and all notifications of school conferences and events. 2. The Mother shall have primary physical custody of the Child. 3. The Father shall have partial physical custody of the Child on alternating weekends fran Thursday at noon through Sunday at 8:00 p.m. and, during the interim weeks from Thursday at noon through Friday at 8:30 a.m. The alternating weekend schedule shall begin with the Mother having custody of the Child for the weekend beginning December 22, 2000. 4. The parties shall share or alternate having custody of the Child on holidays as follows: . , -~ -. ~ fi - . A. CIIlUS'.rMAS: The Christmas holiday shall be divided into Segment A, which shall run fran Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and SegmentB, which shall run fran Christmas Day at 12:00 noon through December 26 at 12:00 noon. The Mother shall have custody of the Child during Segment A in even numbered years and during Segment B in odd numbered years. The Father shall have custody of the Child during segment A in odd numbered years and during Segment B in even numbered years. B. ALTERNAi'ING HOLIDAYS: In even numbered years, the Father shall have custody of the Child on Easter, July 4th and Thanksgiving and the Mother shall have custody on New Years Day, Memorial Day and Labor Day. In odd numbered years, the Father shall have custody of the Child on New Years Day, Memorial Day and Labor Day and the Mother shall have custody on Easter, July 4th and Thanksgiving. The holiday periods of custody under this provision shall run from 5:00 p.m. on the evening before the holiday through 8:00 p.m. on the holiday. C. FATIIER'S DAY/MCmlER'S DAY: The Mother shall have custody of the Child every year on Mother's Day fran 9:00 a.m. on Sunday through Monday morning and the Father shall have custody every year on Father's Day fran 9:00 a.m. on Sunday through Monday morning. D. The holiday custody schedule shall supersede and take precedence over the regular and vacation custody schedules. 5. Each party shall be entitled to have 2 weeks of uninterrupted vacation custody with the Child during the school vacation or holiday periods to be exercised non-consecutively and to include that party's regularly scheduled weekend. Vacation periods under this provision shall not be scheduled to interfere with the holiday custody schedule. Each party shall provide at least 60 days advance notice to the other party of his or her selection of vacation dates under this provision. The party providing notice first shall be entitled to preference of his or her selection of vacation dates. 6. The parties shall share transportation equally on a flexible schedule as work and school schedules permit. This provision shall be subject to review in the event that either party desires to move to a new residence which would be more than 20 miles further fran the other party's residence than his or her current residence is located. 7. The parties shall attend joint counseling with Tressler Lutheran Services to attempt to improve their communication and co-parenting skills, for a minimum of 4 joint sessions. The paternal grandparents will pay for the first 4 sessions. The cost of any further sessions as may be agreed upon by the parties shall be divided equally between the parties. The Father shall promptly contact Tressler Lutheran Services to arrange for the counseling sessions, and both parties shall cooperate as necessary to complete a minimum of 4 joint sessions as soon as practiCable. ~ 'r~, ~- ~ --.-!"'-- I ~ ~- ". 8. 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. cc: Constance P. Brunt, Esquire - Counsel for Father 7 Iri) Samuel L. Andes, Esquire _ Counsel for Mother ~ ,~ J.2-.2 . . '+'"' tt, ,', - .-~ , -,- ,'"'-- , ,- - -~. ,~~~~~~",~iffil~~i;ii!;~jlll;<i!!~.,j!fri&!j;.jf~';!ii,;I.!~~!EJiMW%~~If'll{M'r~" ~~] . ^.~ ~ .., .". ~ . N_ ..~ ".~i#l~~. ;111: "/'"'''''' ~__lIiIIi!Iii~'- ""'= o c S -0""'-' rDr'f-: ~~. ~.....C_, >C~, ZC" )>C', ~ -<. ,::> C) I::;J r'71 C""') ~..) .....J () ':::1'; -n ~ ~.0E? ~'.;.;.J ~~(\ .'_){") [5rn ~ :0 -< --0 ~...... :.,) ,..:) ~ , MATTHEW G. GIBSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 2000-4683 CIVIL TERM . . . MELISSA C. LOPEZ, . CIVIL ACTION - LAW . Defendant : CUSTODY CUSTODY CJCI'ICILIATIOO SUMMARY REPCm IN ACCClIDANCE WITH CUJIIBERLAND <XXlNTlr 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 Kay1ee Drew Lopez January 31, 1999 Mother 2. A Conciliation Conference was held on December 21, 2000, with the following individuals in attendance: The Father, Matthew G. Gibson, with his counsel, Constance P. Brunt, Esquire, and the Mother, Melissa C. Lopez, with her counsel, Samuel L. Andes, Esquire. 3. The parties agreed to entry of an Order in the form as attached. ~ Date cJ. /. ~t)f) . Da~'7 Custody Conciliator "_"'fc !-- -~ ~ . ~ ,-" "' ~ .