HomeMy WebLinkAbout97-00207
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
v,
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NO, ~8 CIVIL TERM
W. JEFFREY CHOVAN,
Plaintiff/Respondent
KAREN R, (CHOVAN) RYAN.
Defendant/Petitioner
CIVIL ACTION - LAW
CUSTODY
ORDER
AND NOW, upon consideration of the attached Petition, it is hereby directed that the
parties and their respective counsel appear before , the Conciliator on the
_ day of , 2000, at ,m, at the offices of
, Pennsylvania, 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 ('nter 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,
FOR THE COURT,
Date of
Order:
Custody Conciliator
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 LA WYER REFERRAL SERVICE
Cumberland County Bar Association
Carlisle, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
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,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
W, JEFFREY CHOVAN,
Plaintiff/Respondent
v,
)
)
)
)
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NO, 1)7-9258 CIVIL TERM
KAREN R, (CHOVAN) RYAN.
Defendant/Petitioncr
CIVIL ACTION - LA W
CUSTODY
PETITION TO MODIFY ORDER OF CUSTODY
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AND NOW, Defcndant Karen R, (Chovan) Ryan, by and her through her attorney,
Howr.tt, Kissinger, P.c. and files a Petition to Modify Order of Custody, and in support thereof,
avers thc following:
I, Pctitioncr is Karcn R. (Chovan) Ryan (hercinafter refcrred to as
"Mother"), dcfcndant in the above-caption cd custody mattcr, who currently rcsides at 103
2, Rcspondcnt is W, Jeffrey Chovan (hereinaftcr rcfcrred to as "Father"),
Wandering Lanc, Harvest, Alabama 35749,
plaintiff in thc above-captioncd custody mattcr. who currently residcs at 1808 Willow Road,
Carlisle, Cumbcrland County, Pcnnsylvania, 17013,
3, The partics hereto are the parcnts ofthc following minor children:
Namc
Datc of Birth
Shaun Ryan Chovan
Dcccmber 12,1989
Devon Leigh Chovan
Deccmbcr 8, 1993
4, On March 30, 1998, the Court cntered an order granting sharcd legal
custody to both partics, and granting primary physical custody to Plaintiff and tcmporary
VERIFICATION
I, Karen R, Ryan, hereby swear and aflirnl that the facts contained in the foregoing
Petition to Modify Order of Cu~tody are true and correct to the best of my knowledge,
information and belief and are made subject to thc penalties of 18 Pa,C,S, *4904 relating to
unsworn falsification to authorities,
Date:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
W, JEFFREY CHOVAN,
Plaintiff/Respondent
)
)
)
)
)
)
)
CIVIL ACTION - LA W
CUSTODY
v.
NO, 97-9258 CIVIL TERM
KAREN R, (CHOVAN) RYAN,
Defendant/Pctitioner
CERTIFICATE OF SERVICE
I, Cindy S, Conley, Esquire, counscl for Karen R, (Chovan) Ryan. Defendant in the
above-captioned action, hereby ccrtify that a truc and correct copy of the foregoing Petition to
Modify Order of Custody was scrved upon Thomas S, Diehl, Esquire, counsel for Plaintiff, W,
Jeffrey Chovan, by depositing samc in the United States mail, first class, on August 15, 2000,
addressed as follows:
Thomas S, Diehl, Esquire
401 East Louther Street, Suitc 103
Carlislc, PA 17013
Date: I~ ~d:J
r:- ~xI r4-
Cindy S, Conley, Esquirc
HOWETT, KISSINGER & CONLEY, P.C,
130 Walnut Strcct
P,O, Box 810
Harrisburg, P A 17108
Telephone: (717) 234-2616
Counsel for Defendant/Petitioner
Karen F, (Chovan) Ryan
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w. Jeffery Chovan and Harrisburg, PA 7/96 - 7/23/96
, Karen R. Chovan
W. Jeffery Chovan and 2702 Waterdown Road 3/93 - 7/96
Karen R. Chovan Huntsville, AL
W. Jeffery Chovan and Gaines Road 1985 - 3/93
Karen R. Chovan Huntsv i lle, AL
The mother of the children is Karen R. Chovan currently
residing at 701 Carriage Lane, Mechanicsburg, Pennsylvania.
She is married.
The father of the children is W. Jeffery Chovan, residing at
1121 Harrisburg Pike, Carlisle, Pennsylvania.
He is married.
4. The relationship of Plaintiff to the children is that of
father.
The Plaintiff currently resides with the following
persons: none.
5. The relationship of Defendant to the children is that of
mother. The Defendant currently resides with the following
persons: the children.
6. Plaintiff has not participated as a party or witness or
in another capacity, on other litigation concerning the custody
of the children in this or another court.
SAID IS, GUIDO.
SHUFF &
MASLAND
26 W. Uigh SIKCI
CarlislC:."A
Plaintiff has no information of a custody proceeding
concerning the children 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 children or claims to
have custody or visitation rights with respect to the children.
2
SAIDIS, GUIDO,
SHUFF &
MASLAND
26 W, High 51"'''
CArlisle,I'A
7. The best interest and permanent welfare of the children
will be served by granting the relief requested because the
children have lived the wide majority of their natural lives with
Plaintiff, and the Plaintiff desires to have a meaningful and
continuing relationship with his children.
8. Each parent whose parental rights to the children have
not been terminated and the person who has physical custody of
the children has 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 children will be given notice of the
pendency of this action and the right to intervene: none.
9. Plaintiff requests that the COurt grant primary phYSical
custody of the children to Defendant Mother and that Plaintiff
have partial Custody and visitation and shared legal Custody.
WHEREFORE, Plaintiff requests the court to grant him partial
custody and visitation of the minor children and to award shared
legal custody to both parties.
Date:
I-I Y~c;7
Respectively SUbmitted,
SAlOIS, GUIDO, ~& MASLAND
By:
ott D. Moore, Esquire
Supreme Ct. r.D. # 55694
26 West High Street
CarliSle, PA 17013
(717) 243-6222
Attorney for Plaintiff
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W. JEFFERY CHOVAN,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
KAREN R. RYAN,
DEFENDANT
: 97-0207 CIVIL TERM
AND NOW, this
ORDER OF COURT
~
day of December, 2000, the custody hearing
scheduled for December 21, 2000, IS CANCELLED. The hearing is rescheduled for
Wednesday, February 14, 2001, at 1 :30 p.m, in Courtroom Number 2.
By the Court,
~lAi
Edgar B.' ayleY, .
Thomas S. Diehl, Esquire
For Plaintiff
Cindy S. Conley, Esquire
For Defendant
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W. JEFFREY CHOVAN,
plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 97-207
CIVIL TERM
.
.
KAREN R. CHOVAN,
Defendant
CUSTODY
aU>IlR OF CXXJRI'
AND t<<:W, this 16th day of April, 1997, the Conciliator, having
received no cOllll1unication fran counsel regarding either scheduling of the
Custody Conciliation Conference originally scheduled for February 25, 1997
or other action in this matter, hereby relinquishes jurisdiction.
~
Custody Conciliator
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LA.. _<:Ill OF
MlluTsKY AND DIEH1.
OMit YftlIT' HIOM 1I11rECT. IVIT1J ZOIt
CA\II1nUl'. f'l'HNIM.YANIA t'fOUI
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WILLIAM J. CIIOVAN.
PlainlifllRespondenl
IN TIll: ('OIIRT OF ('OMMON PLEAS OF
ClIMIlU{I,AN!> CO( INTY. PENNSYLVANIA
v.
NO, 97-207 ('IVII. TUHvl
KAREN F. (C/lOVAN) RYAN.
I >c fe ndant/Pet i t i oner
IN ('IISTO!>Y
NOTICE OF INTENT TO SEI~VE A SUBPOENA TO I'IWDUCE DOClJMENTS AND
THINGS FOR I>ISCOVERY PURSUANT TO RULE -411119.21
The PlainlifllRespondent. William J, Chol'an. intends to serl'e suhpoenas identicallo the
ones that arc attached to this nOliee. You have twenty (2()) days Irom the date lisled helow in
which to file a record and serve upon the undersigned an ohjeetion to the suhpoena, If no
ohjeetion is made the suhpoena may he served,
Dated: 1- t u - or
'homas S. Diehl. ESlJuire
Attorney lor PlaintifliRespondent
One West /Iigh Street
Post Office Box 1290
Carlisle. Pennsyll'ania 17013
(717) 240-0833
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No, 1997.207
WILLIAM J, CIIOY AN.
PlaintifT
v.
KAREN F, (CHOYAN) RYAN.
Defendant
TO: Ms. Ruth Ann Snyder
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl. Esquire
One West High Street. Suite 208
P.O. Box 1290
Carlisle, P A 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance. to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service. the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Attorney's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle.PA 17013
Address
( 7 I 7) 240-0833
Telephone Number
Attorney for: William J. Chovan
BY THE COURT:
DATE: /./? '.0 J
Seal oftlle Coult
(.!uW6 R. dO A'I
Prothonotary
.
:---:--
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. 1997-207
WILLIAM j, CHOVAN.
Plaintiff
v,
KAREN F. (CHOVAN) RYAN,
Defendant
TO: Ms. Gav Walker
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena. you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl. Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle. PA 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within tw~nty
(20) days after its service. the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Attorney's Name
78942
Identification Number
One Wcst High Street. Suite 208
Carlisle. PA 17013
Address
17(7) 240-0833
Telephone Number
Attorney for: William J. Chovan
DA1R)&J. 1ft, c2.f1..~
Seal oCtile C?ljllt' Ii!
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. I 997-lt 0 '1
WILLIAM 1. CHOVAN.
Plainti IT
v.
KAREN F, (CHOVAN) RYAN.
Defendant
TO: Ms. Halteman
(in care of Hamiltan Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle, P A 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance. to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service. the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S. Diehl
Attorney's Name
78942
Identification Number
One West High Street, Suite 208
Carlisle, PA 17013
Address
(717) 240-0833
Telephone Number
Anorney for: William j, Chovan
BY THE COURT:
DATE: I.fIlW',,/,q, /tJ J,.cw
,
Seal of the Court
('/".11,.; // rJ' )......
Prothonotary .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. I 997..;J c 1
WILLIAM J. CHOVAN.
Plaintiff
v.
KAREN F. (CHOVAN) RYAN,
Defendant
TO: Ms, Madden
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena. you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle. PA 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance. to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service. the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Attorney's Name
78942
Idenlification Number
One West High Street. Suite 208
Carlisle. P A 17013
Address
(717) 240-0833
T c1ephone Number
Attorney for: William 1. Chovan
BY THE COURT:
DATE: tJ-HH..IU. /~ :ld7!'J
Seal Qf the Court
fl"'~"; k~ r"d ..
Prot onotary , ,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No, 1997-).01
WILLIAM 1. CHOVAN.
Plaintiff
v.
KAREN F. (CHOVAN) RYAN.
Defendant
TO: Ms. Crystal Brock. Secretarv
Within twenty (20) days after service of this subpoena. you are ordered by !he Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle. PA 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance. to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing !he
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S. Diehl
Attorney's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle. P A 17013
Address
(717) 240-0833
Telephone Number
Attorney for: William 1. Chovan
BY THE COURT:
DATE: J. o,o".k., /1 .2/'t'tJ
Sl:al of the Court '
Cwr.~ /rJ.,p~.
Prothonotary
~~.
v
CERTIFICATE OF SEIWICE
I hereby certify this 16th day of January 200 I. that a true and correct copy of the lilregoing
document was served on the following individuals via certified. Iirst-c1ass mail. postage prepaid:
Cindy S. Conic)', ESlJuirc
1I0wett, Kissin!:er, & Conlcy, I'.C.
t30 Walnut Strcet
1'.0. Dox 810
HlIrrisbur!:,I'A 17108
t
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLV ANIA
WILLIAM j, CHOVAN.
Plainti ff/Rcspondcnt
NO. 'n-207 CIVIL TERM
v.
KAREN F. RYAN.
Dcfcnd.lIll/Pctitioncr
CUSTODY
OBJECTION TO Slllll'OENAS 1'1lRSl'ANT TO RULE 4009.21
Karcn 1', Ryan. Dcfcndant/I'ctitioncr objccts to thc proposcd suhpocnas that arc attachcd
to thcsc ohjcctions for thc following rcasons: Dcfcndant/Pctitioncr bclicvcs th.ltthc discovcry is
bcing sought in bad faith. is not rclcvanlto thc procccding at hand. and is not rcasonably
calculatcd to Icad to thc discovcry of admissiblc cvidcncc.
Datc:
/~9'N
(.~ ~~\!~t~O~
Cindy S. Conlc}\ Esquirc (
,
,
I
(r.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. 1997-207
WILLIAM J. CHOVAN.
Plaintiff
v.
KAREN F. (CHOVAN) RYAN.
Defendant
TO: Ms, Gav Walker
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street. Suite 208
P.O. Box 1290
Carlisle, P A 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Attomey's Name
78942
Identification Number
One West High Street, Suite 208
Carlisle. P A 17013
Address
(717) 240-0833
Telephone Number
Attomey for: William 1. Chovan
DA1B.J2A1. 1ft, cl2.tnL
Seal oCtile C?4,Ilt' I :, i
, . .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY. PENNSYLVANIA
i
J
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. 1997- ,l.01
WILLIAM J. CHOVAN,
Plaintiff
v.
KAREN F. (CHOVAN) RYAN,
Defendant
TO:
Mr. 1"'_='<'1 ~l'i. Prfnroipal
(in care of Hanu ton Elementary School)
Within twenty (20) days after service of this subpoena. you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle, P A 17013
I
'I
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of complIance, to the party making this request al the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S. Diehl
Attorney's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle. PA 17013
Address
(717) 240.0833
Telephone Number
Attorney for: William 1. Chovan
BY THE COURT:
DATE'-Afnt~ /~ :lC7Jv
Seal of the Court
Cu.a:..,. ;e e h-'
Prothontary ""'1', Q
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
SUIJPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
~
t
,
No, I 997..Ic ,.
WILLIAM 1. CHOVAN.
Plaintiff
v,
KAREN F. (CHOVAN) RYAN,
Defendant
TO: Ms. Clements
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle, PA 17013
I
,
,
,
I
I
i
"I
I
t
I
i
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena. together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Anomey's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle. PA 17013
Address
(717) 240-0833
Telephone Number
Allomey for: William], Chovan
BY THE COURT:
DATE: jo,,.,~.~ 11 .2r1Vo
Seal of the Court
('".t',.; /2 ,f ~ -)'_'
Prothonotary
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. 1997-lto'7
WILLIAM J. CHOVAN.
Plaintiff
v.
KAREN F. (CHOVAN) RYAN.
Defendant
TO: Ms. Halteman
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the follo....ing documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O, Box 1290
Carlisle, PA 17013
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S, Diehl
Attorney's Name
78942
Identification Number
One West High Street, Suite 208
Carlisle. PA 17013
Address
(717) 240-0833
Telephone Number
Attorney for: William 1. Chovan
BY THE COURT:
DATE: I.JlnA~~ It) J.4w
Seal of the Court '
('I"~'A r/ rd J.......
Prothonotary , .
,
I
r:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY , PENNSYLVANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
~
~
No.1997';JC7
WILLIAM 1. CHOVAN,
Plaintiff
v.
KAREN F. (CHOVAN) RYAN,
, Defendant
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle. P A 17013
TO: Ms, Madden
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
You may deliver or mail legible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S. Diehl
Attorney's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle. PA 17013
Address
(717) 240-0833
Telephone Number
Attorney for: William 1. Chovan
BY THE COURT:
DATE: ;';",,,.L. /~.:uw
Seal of the Court
fLCAJj /(, /"4 )
prot notary .
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYL VANIA
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY
PURSUANT TO RULE 4009.22
No. 1997-\:2D7
WILLIAM 1. CHOVAN,
Plaintiff
v.
KAREN F. (CHOVAN) RYAN.
Defendant
TO: Ms. Ruth
(in care of Hamilton Elementary School)
Within twenty (20) days after service of this subpoena, you are ordered by the Court to
produce the following documents or things: any correspondence written by Karen F. Ryan at:
Thomas S. Diehl, Esquire
One West High Street, Suite 208
P.O. Box 1290
Carlisle, PA 17013
You may deliver or maillegible copies of the documents or produce things requested by
this subpoena, together with the certificate of compliance. to the party making this request at the
address listed above. You have the right to seek in advance the reasonable costs of preparing the
copies or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service. the party serving this subpoena may seek a Court Order compelling
you to comply with it.
This subpoena was issued at the request of the following person:
Thomas S. Diehl
Attorney's Name
78942
Identification Number
One West High Street. Suite 208
Carlisle. PA 17013
Address
(717) 240-0833
Telephone Number
Attorney for: William J, Chovan
BY THE COURT:
DATE: Akuj<'-~" / 9 U'6V
Seal of the Court
&'A7,_' fJ. ,f~, ..
Prothonotaru '
. ,.. PJ j
. ~IB~ . ,j i U~d
.!.~:I! II ~~ ~I
. .!l t; ~ -
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~ II Ii !j
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. ,~... ....
.. .
-. .
w. JEFFREY CHOVAN,
plaintiff
IN THE OOURT OF CXXo\MON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
vs.
: NO. 97-0207 CIVIL TERM
.
.
CIVIL ACTION - LAW
IN CUSTODY
KAREN R. (CHOVAN) RYAN,
Defendant
CIU>ER OF <XXlRT
AND t<<:W, this :)/A day of "--\:. f( (<l
upon consideration of the attached CUstody conciliation
ordered and directed as follows:
1. A Hearing is scheduled in Court Room # ,-:;, of the
rland County Court House, on the . ;'/S~ day of
:, t"d'tJ/L , 2000, at ';. -1'5 o'clock, (" .m., at which time
test mony w 11 be taken. For purposes of the Hearing, the Mother, Karen R.
Ryan, shall be deemed to be the moving party and shall proceed initially
with testimony. counsel for the parties shall file with the Court and
opposing counsel a Memorandum setting forth each party's position on
custody, a list of witnesses who are expected to testify at the Hearing,
and a surnnary of the anticipated testimony of each witness. These
Memoranda shall be filed at least ten (10) days prior to the Hearing date.
, 2000,
Report, j,t is
2. The parties shall submit th~maelves and their Children to a
custody evaluation to be performed by Arnold Shienvo1d, PhD. The purpose
of the evaluation shall be to obtain independent professional
recOllll1endations 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 Children. The cost
of the evaluation shall be equally shared by the parties.
3. pending further Order of Court or agreement of the parties, the
parties tentatively agree that the Father shall have custody of the
Children over the Thanksgiving holiday in 2000 and shall transfer custody
of the Children to the Mother for the Christmas holiday in Kentucky on
Christmas Eve by 1:00 p.m. or other time arranged by agreement of the
parties. The Mother shall provide transportation for the Children to
Pennsylvania before school resumes after the Christmas holiday, for which
the Mother reserves the right to have the Court appoftion the coats.
BY THE i
/
,
J. ~
_".J9~ 0
(:<<\D'9~
ee: Thomas S. Diehl, Esquire - Counsel for Father
Cindy S. Conley, Esquire - counsel for Mother
(
~
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,
c.:
,., ..'~' y
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'i:J\1 ~, , ,
L '""
.
I
f'
W. JEFFREY CHOVAN,
Plaintiff
.
.
IN THE COURT OF OOMMOO PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
VB.
NO. 97-0207 CIVIL TERM
.
.
KAREN R. (CHOVAN) RYAN,
Defendant
.
.
CIVIL ACTIOO - LAW
IN CUSTODY
.
.
PRIClt JUDGE: Edgar B. Bayley
CllSTOOY CXH:ILIATlOO StMIARY REPCRT
IN ACXXlIDANCE WITIl <nlBERLAND CXXNl'Y RULE OF CIVIL PR.:' .....(JRE
1915.3-8, the undersigned CUstody Conciliator submits the following report:
1. The pertinent information concernio;J the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTII
aJRRml'Ly IN CllSTOOY OF
Shaun Ryan Chovan
Devon Leigh Chovan
December 12, 1989
December 8, 1993
Father
Father
2. A Conciliation Conference was held on September 20, 2000, with the
following individuals in attendance: The Father, W. Jeffrey Chovan, who
appeared without his counsel, Thomas S. Diehl, Esquire, and the Mother,
Karen R. (Chovan) Ryan, with her counsel, Cindy S. Conley, Esquire.
3. On November 30, 1998, this Court entered an Order based on a
Stipulation of the parties, under which the Father had primary physical
custody of the Children and the Mother, who then lived in Baltimore,
Maryland, had partial custody on alternating weekends, alternating holidays
and four weeks in the surrrner. The Mother moved back to Alabama, where the
parties previously resided, and filed this Petition for Modification
seekio;J primary physical custody of the Children. The parties were not
able to reach an agreement as to ongoing custody arrangements and it will
be necessary to schedule a Hearing. However, the parties agreed to obtain
an updated evaluation from Arnold Shienvold, PhD., who had previously
iSBUed custody recommendations in 1998.
4. The Mother's position on custody is as follows: The Mother seeks
primary custody of the Children. As one alternative at the Conference, the
Mother proposed that she have custody of the Children during the majority
of the surrrner school break, durio;J every Sprio;J break, during alternating
Thanksgiving school breaks and during the school break over the Christmas
holiday with the exception of Christmas Eve and Christmas Day which could
be alternated. The Mother believes the Children should be permitted to
travel on direct flights with airline supervision, for all exchanges of
custody when the Father is not in Alabama, Kentucky or Tennessee visiting
relatives where the parties could exchange custody without curtailing the
length of the Mother's periods of custody with the Children. The Mother
would be willing to fly with the Children if the Father were willing to
share the cost of her ticket. The Mother believes the Father is being
unreasonable by both refusing to allow the Children to fly unless the
Mother personally accompanys the Children and to share the cost of the
Mother's airline expenses. The Mother objects to the Father's suggestion
that they exchange custody by driving to a halfway point because the travel
time would considerably shorten her periods of custody with the Children.
5. The Father's position on custody is as follows: The Father
objects to the Mother's request for primary physical custody of the
Children. The Father does not believe that the Children are old enough at
ages seven and eleven (as of December 2000) to fly alone without parental
supervision. However, the Father is not willing to incur the expense of
flying with the Children or to share the cost of the Mother's airline
expenses to accanpany the Children. The Father proposes that the parties
exchange custody by driving to a halfway point and adjust the custody
schedule as necessary depending on the Father's work schedule and the
driving time.
6. The parties were able to agree on temporary custody arrangements
pending the Hearing and also to proceed with an additional custody
evaluation by Arnold Shienvold, PhD. The Conciliator recOllll1ends an Order
in the form as attached reflecting the parties' temporary agreement and
scheduling a Hearing in this matter. It is expected that the Hearing will
require at least one half day.
~~
Date
Q,. ~oe,
Dawn S. Sunday, Eaqu re (j
Custody Conciliator
dJ. J. riQoI")
.