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Home My WebLink About00-05187 -~ ~ "-~, '--, ~ - ~ "-, K1RAN KUMAR DANDAPAT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y, PENNSYLVANIA PLAINTIFF V. MANASWITA DANDAPAT 00-5187 CML ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, this 27th day of July ,2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on the 21st day of August ,2000, at 9:00 AM 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 confer~nce may provide grounds for entry of a temporary or permanent order. FOR TIIE COURT, By: Isl Melissa P. Greevy. ESq( 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 HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TI!E OFFICE SET FORTI! BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ;f,i;;;;;X)'~'?,-::;'.'!~"'::'" !~o~If\:a~l~iitlijL..... ,<""""".c, ~"f~_ CY: -1 ~ ::.. 00 JUL 23 : z: ~~i 3 C: 1\-1.:'-'- ... :.i ((.i 11\!T'y' ,,,..',~,'-'.....: h...! ,) -,,~, 'J~,il", -. i PENNSYi\/.A!\l:J~ '7-01600 &vI- ~<~ ~ ~ ~ 7';X-~t:1 ~11~ ~ Z, d;/f- ;'dltj-OCl ~ ~ ?f;. a{/ ~ ",~~M'-1'MII!IllI ~T'~~ _ ~~~~~!Mjl;.i~I"li""j1!!!il~ ~ _...d.__._"",.Il!I!llr:;1l1~~''1_"....~ , ,",-' ,~"",,:",'!"" ~, - -,' ,'c,'_ _ ,c.'.-, __, _ _., -V""''''y'J.;,,-,,- -,f~ ,',", ,:'_C_,,-._,-,,"'--_-__ -,/<':;;'f~_',-",,>/ '. -~~ >-"",,,' GOLDBERG, KATZMAN & SHIPMAN, P.C. PaulJ.Espos.ito,Esqulre Supreme Court ID #25454 320 Market Street, P.O. Box ]268 Harr1sburg, PA ]7]08-1268 Attorneys for PlaIntiff K1RAN KUMAR DANDAPAT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERlANDCOUN1Y, PENNSYLVANIA v. NO. t:O - 5/t7 itJ MANASWlTA DANDAPAT, Defendant CMLACTION -LAW CUSTODYMS1TATION ORDER OF COURT AND NOW, this day of , 2000, upon consideration of the within 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. Either party may bring the child who is the subject of this custody action to the Conference, but the child/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: By: 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. Office of the Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240,6200 cc: Defendant Paul J. Esposito, Esq. "," ,', "" " . ~ "~," - '-"-"'''''- ,.n. ,_" ",", ,."" . """ , .,.~.,,;;,-. ~'.t_,';,'.L""':" ~--~'_";;;.- -,-.', KIRAN KUMAR DANDAPAT, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVAN~ NO. ()'()- 5tf1 6;;J --r~ MANASWlTA DANDAPAT, Defendant CML ACTION - LAW CUSTODYMS1TATION COMPLAINT FOR CUSTODY 1. Plaintiff is K1RAN KUMAR DANDAPAT, who currently resides at 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania. 2. Defendant is MANASWlTA DANDAPAT, who is currently residing at 38-R Lancaster Avenue, Enola, Cumberland County, Pennsylvania. 3. The parties are husband and wife, having been married on July 13,1995, and separated on or about December 27, 1999. 4. Plaintiff seeks shared physical and legal custody of: Name: Shankar Kumar Dandapat, DOB: 9122197 Present Residence: 38-R Lancaster Avenue, East Pennsboro Township, Cumberland County, Pennsylvania The child was not born out of wedlock. 5. The child presently resides with Manaswita Dandapat, Defendant herein, at 38-R Lancaster Avenue, Enola, Cumberland County, Pennsylvania. Since birth, the child has lived with the following persons and at the following addresses: -" ,~,'" "'"- - " -.,., '-.'"" ,"^ " _ >r:, ,. - "'_-;';'/;'f'''~i;,' ,-, :,~,,, "." ".,;__' '. - 0 ,: ". ~",-,:"'>,,<'" .".'.., 9/22/97 - 7/24/99 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania Plaintiff and Defendant 7/24/99 - 8/99 Location unknown to Plaintiff Defendant 8/99 - 9/99 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania Plaintiff and Defendant 9/99 - 10/15/99 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania Plaintiff, Defendant and Defendant's Father 10/15/99 - 12/27/99 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania Plaintiff and Defendant 12/27/99 - 1/6/00 Location unknown to Plaintiff Defendant 1/6/00 - Present 38-R Lancaster Avenue, Enola, Cumberland County, Pennsylvania Defendant The mother of the child is MANASWlTA DANDAPAT, Defendant herein, who is currently residing at 38-R Lancaster Avenue, Enola, Cumberland County, Pennsylvania. She is married to the Plaintiff. The father of the child is KIRAN KUMAR DANDAPAT, Plaintiff herein, who is currently residing at 852 Erford Road, East Pennsboro Township, Cumberland County, Pennsylvania. 2 , , ~~-;~- -"" "'.J, - ,-<,'..:"',:;--~;;:,~- >" >"-,~: '_I"j; ,-.,i<c. '",..,',,-,,-_ p,'M ". He is married to the Defendant. 6. The relationship of Plaintiff to the child is that of father. Plaintiff currently resides alone. 7. The relationship of Defendant to the child is that of mother. Defendant currently resides with the child. 8. 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. 9. Plaintiff has not seen his child since on or about March 25, 2000, in that Defendant has prevented him from doing so. 10. The best interests and permanent welfare of the child will be served by the relief requested. 11. Plaintiff has not participated as a party, witness or in another capacity or in other litigation concerning the custody of the child in this or another Court. 12. Each parent whose parental rights to the child have not been terminated and the persons who have physical custody of the child have been named as a party to this action. WHEREFORE, Plaintiff respectfully requests that the court grant the parties shared I .~ ".-, ." -. < , ,-" "";'_C_,"" ""_'_~' '. "'4-' - ,--~-" ,~ , legal and physical custody of SHANKAR KUMAR DANDAPAT. Respectfully submitted, , -~-- '-'-."-'~'.., ',- -, GOLDBERG, KATZMAN [,. SHIPMAN, P.c. By fkt i Paul J. osit , Esquire 320 Market Street Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Plaintiff ,,-, ,-:;;" --- ,-,,-~ 'io.-;--," ;';, "_"'<"-"'~_;':'" ____,;,-_,,,_,,._'0 <.,,,,;;, '','.>-___, -,'_,',,_". ._,. --" "," ,-~" ~"""!I , ' VERIFICATION I verify that the statements contained in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.c.S. Section 4904 relating to unsworn falsification to authorities. Date: 07/ { f J OD LA.' i\ - # I"J\ r tlV\ ~ KIRAN KUMAR DANDAP P1. (If"" '-~' ,,';-,- '"--', ~-- . -~. , -- " '-. - ~ "---'---~'~" - :,;- ':ai--=" ,~ ~.) ~ <:>\\ ~ ~~ ~ -~-- -- " -~ 'l: ,~ ~ ~ Y', t~ \~ ~ '1 ~ \~ ~ \ \ \ , '\. ~~ o ((-~~,~ ~~ 33.1~}:.: "r- __ ....,) &~~ ':-_" ", ~..... ,. T--:: ."0 t?f; ~;' ..<>~;;; """] '...'1 =< C....) . t. ".',' ,. ,. .,,,',~."" _.. ",-.:' , ",L'l~_;;'~"'.'~'''''" . '>,",..<,-,;" ",i. ,"<:-'" "'~;';';~" ',;.' j~'( '. . Goldberg, Katzman & Sbi_ P.C. Paul J. Esposito, Eaquire - I.D. #25454 320 Market Street Post Office Box 1268 Harriaburg, PA 17108.1268 Attorneys for Plaintiff KIRAN KUMAR DANDAPAT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 00-5187 CIVIL MANASWITADANDAPAT, Defendant CIVIL ACTION - LAW IN CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) ) SS: COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on August 1, 2000, he sent a certified copy of a Complaint for Custody by certified mail, return receipt requested, restricted delivery, to Manaswita Dandapat, 3 8-R Lancaster Avenue, Enola, P A 17025, and the return receipt card signed by Manaswita Dandapat, and shown as being delivered _. 4, ZOllO, ""'~hoI i<reto "'" ""'" :y~ PAUL . E OSITO, ESQUIRE Sworn to and subscribed before me. this 7th Notary PubIi Notarial Seal Victoria Y. Chambers, Notary Public Harrisburg, Dauphin County My Commission Expires Apr. 7. 2003 My Commission Ex ires: ..--..... . ' 'em~ft,' Z/~lici 3::~A1S6c't:bffii'I'ete item 4 if Restricted ,Delivery is desired. . Print your name and address on the reverse s6\'that we can return the card to you. . Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: C. Signature ~~ o Agent Add. DYes o No e D, Is delivery address different from item 1? If YES, enter delivery address below: P'\S. ~,,"a-. ~~ ~-r< ~ Are- ffro\a. ~ \7o;;tS , 3. Service Type "ijIC,Pertifled Mail 0 Express Mail -tJ Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delive~~,@Xtra Fee) es '. ~"'~~ ,';';"'" / - ,'.---- ~.99~M~1'189' Jii~'-- ~ - ... -', ~ ~-. --".- ,.". ~ ~. ,~, ~ ;-c-'-'-' ~ ~ ., -., .. , ~ " _c~:-~ > '~ _, "", ..C,. ""'j (") C) () c: C) '-i-' s: ~ -om ,-- nlm ~:;=) , , Z::o .:--"1 zr;: I ,:-c;::-' (f) ~.~. co ~ ,-'''' -<Z -,~ <0 -0 ~~ ,+{ ;';;0 "~. ~~~ -~~ =0 c"" Pc: :.:..j ~ -po :a -< f' _.",c, -~ 'O'-n''-)-_< _ _, ., .' . GOLVBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito, Esquire - I.D. #25454 320 Market Street Post Office Box 1268 Harrisburg, PA 17108-1268 Attot1leys for Plaintiff KIRAN KUMAR DANDAP AT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA v. NO. 00-5187 MANASWlTA DANDAP AT, Defendant CNIL ACTION - LAW IN CUSTODY TO THE PROTHONOTARY OF DAUPHIN COUNTY, PENNSYLVANIA: Kindly withdraw the appearance of Goldberg, Katzman & Shipman, P.C., and Paul J. Esposito, Esquire, in behalf of the Plaintiff in the above-captioned matter. Date: 512!/{}} I I GOLDBERG, KATZMAN & SHIPMAN, P.e. By py~ Supreme Court ill #25454 320 Market Street Post Office Box 1268 Harrisburg, P A 17108-1268 (717) 234-4161 ". , ~ ',_ ,- '., .',,', 'c>;" "'. _ '~ ".' '" -_, r ",_ -.'" >,-,,, j -. . . CERTIFICATE OF CONCURRENCE I, Kiran K. Dandapat, Plaintiff, have read the foregoing Praecipe to Withdraw Appearance in my behalf, and hereby consent to the relief sought in said Praecipe. Date: 0 s; - ?- \ - 1-001> Kiran ~~::;t,' Plaintiff --Ii;',' ,-~; '" ' ",' '." ~,~,--, -,,;!' --'-t ., . , CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Mr. Kiran K. Dandapat P. O. Box 11722 Harriburg, P A 17108-1722 Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.e. By: Date: May:? f , 2003 95893.1 ,.{ "_iIl'tI CillrBr-r--'" I __"",,__C . -- ~> ,-,~. - c (") 0 0 C <;..> -n "" ::1t ::;:! -- -on::: ":P" [-:f\~ rnr" -"'" Z::L' , z....... N ;39 (]5 ':-- 0J ~t:~,1 '-~_ic) -0 \-n j=;- ~-., ::1t ;~ %i:-) r:-? 5>.::: --, ~ I'"" .". :2 00 ".J :::<; - -,' " . ~>"~,; KIRAN KUMAR DANDAPAT, PLAINTIFF/RESPONDENT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MANASWITA DANDAPAT, DEFENDANT/PETITIONER 00-5187 CIVIL TERM ORDER OF COURT AND NOW, this -----17 day of August, 2003, a hearing on the petition of the mother for relocation and modification of custody order, shall commence at 1 :30 p.m., Tuesday, September 16,2003, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. EdgarB.Ba /Stephanie L. Mihalko, Esquire For Defendant/Petitioner ? 4fJ!P- ~)i.3 Og-j3 -03 /Kiran Kumar Dandapat P.O. Box 11722 Harrisburg, PA 17108-1722 :sal " !":=-D-O~FICE OF ','-, :'-Ti-<~;\'OTAFiY t.'" '..r II' I -, U,,];J r":;i 1 J ')i{ 2' OQ l J j _- I ..- (V'!U'~;''''-''_''.,:, '. ',~-;",'" ' i', , ! I: "\I~r'Ji I ., ,_ ,L, '-'".lJj'l PENNSYLVANIA I ~ ~ ii [J ,i ~ m 'i I !'~T "~~ _,~~_~~<l"Ifl'," < - ~ '" ., ~--" ,,-~~- ~"^ _L_,I'!.If!~~."'" ,""',' ......... "II, ~- ~~ ,~_. - " -, --'';'-\11 KIRAN KUMAR DANDAPAT, Plaintiff, * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYL VANIA * VS. * NO. 00-5187 * MANASWITA DANDAPAT, Defendant. * CIVIL ACTION - LAW * CUSTODY PETITION FOR RELOCATION AND MODIFICATION OF CUSTODY ORDER AND NOW, Petitioner, Manaswita Dandapat, by and through her attorney, Stephanie L. Mihalko, Esquire, files this Petitio,n for Relocation, and in support thereof, avers the following: 1. Petitioner is Manaswita Dandapat, Mother, Defendant in the above-captioned custody action, who currently resides at 210 Senate Avenue, Apartment #219, Camp Hill, Pennsylvania 17011. 2. Respondent is Kiran Kumar Dandapat, Father, Plaintiff in the above-captioned custody action, who currently resides at P.O. Box 11722, Harrisburg, Pennsylvania 17108-1722. 3. Mother and Father are currently separated. 4. Mother and Father are the parents of the following minor child, Shankar Kumar Dandapat, who resides with Mother at 210 Senate Avenue, Apartment #219, Camp Hill, Pennsylvania 17011. 5. Mother has primary physical custody of the child. Father has partial physical custody of the child, although, on his own choice, Father has not exercised his custody rights since September 28,2000. 6. Mother believes, and therefore avers, that it is in the best interest of the child and herself that she and the child move to Seattle, Washington, subject to an appropriate partial physical custody schedule for Father. Mother believes the best interest of the child will be served if her ~~", , , IllY relocation is granted for the following reasons: a,) Father has not exercised his custodial rights since September 28,2000, the day after Father attempted to burn down the marital residence. b.) Father has not made any attempts to be a part of the child's life since September 28,2000. c,) The child is not comfortable with the idea of spending time with father because the child does not know father, d.) Father has been physically and verbally abusive to Mother on numerous occasions. The child has been a witness to this behavior by father numerous times. Mother fears for she and her son's safety. e,) Father is an alcoholic and acts irrationally/dangerously during his drinking binges. 7. Along with the above stated reasons, the advantages of the proposed move to Seattle, Washington are numerous, The move will benefit the child and Mother financially, socially and emotionally and will substantially improve the quality oflife for Mother and the child. 8, Mother's motivation for moving is solely to improve the quality oflife for the child and herself Mother is not motivated in any way by a desire to frustrate the relationship between Father and the child. 9, A custody arrangement can be established that will allow Father contact with the child if he so desires.. The child will have an opportunity to continue and maintain a meaningful relationship with Father, and Father will have the opportunity to share in the love and rearing of the child, 10. Mother's proposed move is not the result of monetary whim; rather, Mother has carefully considered the options that are available to her. 11, The Seattle, Washington area provides excellent opportunities to Mother to advance her career because: there are many job opportunities; there are appropriate schools for the child, --, - ~, "' r~' Mother will no longer fear for her safety and can move on with her life. This will be a benefit for Mother and child. 12. These opportunities are not available where Mother and the child presently live. 13. Mother has friends in the Seattle, Washington area. 14. Mother would like to relocate with the child as soon as possible. 15. If relocation is granted, Mother is willing to expand the current custodial arrangements and shall pay the transportation costs for the child's time with Mother. 16. The Order of Court dated September 5, 2000, and attached hereto, provides Mother shall be permitted to have the Child visit India. Father has refused upon numerous attempts by Mother to sign the Passport Application required in order for the child to visit India with Mother. Mother wishes to vacation in India for the child to visit family and experience his culture. 17. The child's needs are inextricably bound to the health and happiness of Mother. The child's welfare cannot be severed from that of Mother, with whom he resides and upon whose well- being he depends. ~ -~ ~"~, WHEREFORE, Mother respectfully requests that this Honorable Court enter an Order: (1) awarding the parties shared legal custody; (2) granting Mother primary physical custody and authorizing Mother to relocate with the child to the Seattle, Washington area; (3) granting Father an appropriate partial physical custody schedule and (4) Order Father to sign the Passport Application for the child to visit family in India and experience his culture with Mother. Date: 7- I a 9 Ib3 Respectfully submitted, ~"')~.~ Stephanie L. Mihalko, Esquire Wiley, Lenox, Colgan & Marzzacco The Wiley Group 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 Supreme Court ill #86998 Counsel for Defendant - ~ -,- ,';",','--- ~,-~'''-<-;:---<<~r,['~_ "~,..-,,,"_~, .,_",,~_~~,_ J'~- .- "'; - ~-,,,,,:';;':j [g)~[Q) SEP 0 1. 2aoatf KIRAN KUMAR DANDAPAT, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5187 MANASWITA DANDAPAT, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this ..1-fh day of , 2000, upon consideration of the attached Custody Conciliation ummary Report and the agreement of the parties it is ordered and directed as follows: 1. The parties shall have shared legal custody of the minor Child, Shankar Kumar Dandapat, born September 22, 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 his health, education and religion. 2. Physical custody of the minor Child shall be arranged as follows: To commence August25, 2000, from Friday at5:30 PM until 8:30 PM on Saturday, and on September 8, 2000, from Friday at 5:30 PM until 8:30 PM on th.e following Saturday, Father shall have physical custody of the Child. To commence on September 22, 2000, on alternating weekends from Friday at 5:30 PM until Sunday at 8:30 PM Fath<er shall have physical custody of the Child. ' 3. During the week, to commence on the week of August 21,2000, on alternating weeks, Father shall have physical custody of the Child on Mondays_and Wednesdays from 5:30 to 8:30 PM. To commence the week of August 28, 2000, on alternating weeks Father shall have physical custody of the minor Child on Tuesdays and Thursdays from 5:30 to 8:30 PM. 4. Transportation shall be shared by the parties. The party commencing their custodial time shall be the party to provide transportation. The party shall wait in the car for the Child. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. The parties shall endeavor to make telephone calls concerning custodial arrangements outside of normal business hours and confine telephone calls during working hours to emergencies regarding the Child. 7. Father shall have physical custody of minor Child for the picnic to honor the Bridge Engineers Appreciation Day which occurs approximately every six months. Father - ':c:'-;'-';"_" shall provide Mother with a thirty-day notice of this event. The custodial period for this day shall be from Noon until 9:00 PM. 8. Mother's Day shall be with Mother and Father's Day shall be with Father from 1 0:00 AM until 8:30 PM. 9. Birthday of the Child: Father shall pick up the Child at 6:30 PM on September 22, 2000, for his birthday weekend. In the event that the Child's birthday falls on the weekend, Father and Mother will alternate sharing the birthday weekend as they occur with each other so that Mother will have the weekend in the year 2001. Any year thereafter the parties will alternate weekends upon which the Child's birthday may fall. It is the expectation that the party cooperating to allow the alternating of birthday weekends shall trade another weekend occurring during the month of September to accommodate this schedule. 10. The following holidays shall alternate between the parties beginning with Father having Labor Day, 2000. The custodial period shall be from 8:00 AM until 8:00 PM. Holidays to be included in this alternating arrangement shall include Labor Day, Thanksgiving, Easter, Memorial Day and July 4th. 11. The Christmas and New Year's holidays shall be alternated between the parties as follows: In even-numbered years Father shall have December 25th at 8:00 AM until December 29th at 8:00 PM. In even-numbered years if December 24th does not fall during Mother's custodial period Mother shall have custody from December 24th from 8:00 AM until 8:00 PM. In even-numbered years Mother shall have December 29th at 8:00 AM until j January 1st at 8:00 PM. The schedule shall reverse in odd-numbered years with Mother having the period of December 25th through 29th, and Father having the period of December 29th through January 1st. 12. Vacation: Mother shall be permitted to have the Child for a period of three weeks for a trip to India to be taken in January or February of the year 2001. Mother shall post a performance bond in the amount of $1,500 t'o be held by her counsel; Michael Travis, in his trust account, which sums shall be returned to Mother upon her return from her trip to India. "- 13. Parties shall share summer vacation as agreed. If the parties cannot agree then they may petition for an additional Conciliation Conference prior to making their summer plans. BY THE COURT, cc: Paul J. Esposito, Esquire Michael S. Travis, Esquire Isj~) /11k~1 i;',",,", . . KIRAN KUMAR DANDAPAT, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5187 MANASWITA DANDAPAT, 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 Shankar Kumar Dandapat September 22,1997 Mother 2. A Conciliation Conference was held on August 21, 2000, with the following individuals in attendance: The Father, Kiran Kumar Dandapat, and his counsel Paul J. Esposito, Esquire; and the Mother, Manaswita Dandapat, and her counsel, Michael S. Travis, Esquire. 3. An Order in the form as attached was agreed upon by the parties. ~q/74lf7J JI,~2& Melissa . eel Greevy, Esquire Custody Conciliator Date "- - .J_ j,' I' ,. VERIFICATION I, Stephanie L. Mihalko, Esquire, on behalf of my client, Manaswita Dandapat, hereby swear and affirm that the facts contained in the foregoing Petition for Relocation are true and correct upon facts stated by Manaswita Dandapat and are made subject to the penalties of 18 Pa. CS. Sec. 4904 relating to unsworn falsification to authorities. Date: '7-- J ~~ 110 t / ~UJ~~,LJ ,i. ~ Steph;nie L. Mihalko, Esquire ........' ,;..-,-- ""'-- .'-"'""~iiii,.tr.li:1i..;i€I.'.',-m~"-"l-5;~~~iIU;",#j.,W.~'o;~k'""j""",;,,~1;:1iill.....AMiiili);;"wlt-- >' ,,~.~ ~ ~WMitJL ~>-~ llW.&i I"'~ll. ~1lIIl~, -'-~~~~" ~ [ -L;J. d 0 0 c ;:,~ ""I". 1-.; () -rJ(L"j 1>- n-i l1]C': -~) ~l.~ ~ 0 ?:?,,'--,-- , -""1:--' r (:;:'1)> '. : ;'lj - -<:----' " ~,~(:) f !<,C 2:':", " L~ --i.i t'?-'(~) __OJ :~:~(~ :.P,-'- ' ':;;n: J L. ;',) ~ -~ :D -, <]j -< ~ r' """'<u KIRAN KUMAR DANDAPAT, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. NO. 00-5187 CIVIL ACTION - LAW MANASWITA DANDAPAT, Defendant IN CUSTODY PRAECIPE TO WITHDRAW AND DISCONTINUE TO THE PROTHONOTARY: Kindly withdraw and discontinue the Petition For Relocation and Modification of Custody Order in the above referenced matter. ~.qAlLv~) I. ~ . tephanie L. Mihalko, Esquire Wiley, Lenox, Colgan & Marzzacco, P.C. The Wiley Group 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 Date: 9 ) It) J tJ:) I I :I"'" "~_~,'""""o "~!ima~1M.~~~liJi~~lfj!~!Mtip; - ~-, "' _M '~~ - , "-~~ ,,~ ",""""'7" "' o c < -ueJ fTir:" z:':: /'" ....-"', C/) ,- -< Ge' 5> --~ Z" i", ;D.c': "7 ~ -< "",< <-,.-,-,' ,', C) C,,J t'J) (....., -a o 'T1 ::.-j ,,:i~g r:D .....0 '-" :'" 0' ~-~ ~ (") :''')ffl :::. ~. :6 "< " ~ ~ if; it; f [, I,; I' Ii; I i ~ i " "",,1 , .. l " SEPOl.tP KIRAN KUMAR DANDAPAT, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5187 MANASWITA DANDAPAT, Defendant CIVIL ACTION - LAW CUSTODY ORDER OF COURT AND NOW, this >1-- day of .,.\\". consideration of the attached Custody Conciliation Summary R parties it is ordered and directed as follows: ,2000, upon ort and the agreement of the 1. The parties shall have shared legal custody of the minor Child, Shankar Kumar Dandapat, born September 22, 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 his health, education and religion. 2. Physical custody of the minor Child shall be arranged as follows: To commence August 25, 2000, from Friday at 5:30 PM until 8:30 PM on Saturday, and on September 8, 2000, from Friday at 5:30 PM until 8:30 PM on the following Saturday, Father shall have physical custody of the Child. To commence on September 22, 2000, on alternating weekends from Friday at 5:30 PM until Sunday at 8:30 PM Father shall have physical custody of the Child. 3. During the week, to commence on the week of August 21,2000, on alternating weeks, Father shall have physical custody of the Child on Mondays and Wednesdays from 5:30 to 8:30 PM. To commence the week of August 28, 2000, on alternating weeks Father shall have physical custody of the minor Child on Tuesdays and Thursdays from 5:30 to 8:30 PM. 4. Transportation shall be shared by the parties. The party commencing their custodial time shall be the party to provide transportation. The party shall wait in the car for the Child. 5. Neither party shall do or say anything which may estrange the Child from the other parent, injure the opinion of the child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Each parent shall ensure that third parties also comply with this provision during his or her periods of custody. 6. The parties shall endeavor to make telephone calls concerning custodial arrangements outside of normal business hours and confine telephone calls during working hours to emergencies regarding the Child. 7. Father shall have physical custody of minor Child for the picnic to honor the Bridge Engineers Appreciation Day which occur!,> approximately every six months. Father ou _ ',_ ~<_"< ' r , " -~ ~ t .. ,- shall provide Mother with a thirty-day notice of this event. The custodial period for this day shall be from Noon until 9:00 PM. 8. Mother's Day shall be with Mother and Father's Day shall be with Father from 10:00 AM until 8:30 PM. 9. Birthday of the Child: Father shall pick up the Child at 6:30 PM on September 22, 2000, for his birthday weekend. In the event that the Child's birthday falls on the weekend, Father and Mother will alternate sharing the birthday weekend as they occur with each other so that Mother will have the weekend in the year 2001. Any year thereafter the parties will alternate weekends upon which the Child's birthday may fall. It is the expectation that the party cooperating to allow the alternating of birthday weekends shall trade another weekend occurring during the month of September to accommodate this schedule. 10. The following holidays shall alternate between the parties beginning with Father having Labor Day, 2000. The custodial period shall be from 8:00 AM until 8:00 PM. Holidays to be included in this alternating arrangement shall include Labor Day, Thanksgiving, Easter, Memorial Day and July 4th. 11. The Christmas and New Year's holidays shall be alternated between the parties as follows: In even-numbered years Father shall have December 25th at 8:00 AM until December 29th at 8:00 PM. In even-numbered years if December 24th does not fall during Mother's custodial period Mother shall have custody from December 24th from 8:00 AM until 8:00 PM. In even-numbered years Mother shall have December 29th at 8:00 AM until January 1st at 8:00 PM. The schedule shall reverse in odd-numbered years with Mother having the period of December 25th through 29th, and Father having the period of December 29th through January 1st. 12. Vacation: Mother shall be permitted to have the Child for a period of three weeks for a trip to India to be taken in January or February of the year 2001. Mother shall post a performance bond in the amount of $1 ,500 to be held by her counsel, Michael Travis, in his trust account, which sums shall be returned to Mother upon her return from her trip to India. 13. Parties shall share summer vacation as agreed. If the parties cannot agree then they may petition for an additional Conciliation Conference prio?'to aking their summer plans. '"'I . ,'" J l BY THE;ICOUR1;! ' I / , cc: Paul J. Esposito, Esquire Michael S. Travis, Esquire .. J~ t~-~.OO f.~5 r~ .. '- t ~ .. --~- " ~- '~ ,~ _,~~ _~_~1I~ ,---, ,.---,', .. ,- SEP -b ,:!'1 8:?O [,, ".f":':" . ,v"U'''T\( 'UI",L.J~II,\_!'--,.: "L,J lj~) "j\, , PENNSYC/i\I\]li\ c__ ~ )'M'i~~fM!f-R"l~'QlUIlll)lll[~_, , ~ ~<" ~ <r.' . ,,- '. ~ -~- '-'-l"";.. r (', > KIRAN KUMAR DANDAPAT, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5187 MANASWlTA DANDAPAT, 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 Shankar Kumar Dandapat September 22, 1997 Mother 2. A Conciliation Conference was held on August 21, 2000, with the following individuals in attendance: The Father, Kiran Kumar Dandapat, and his counsel Paul J. Esposito, Esquire; and the Mother, Manaswita Dandapat, and her counsel, Michael S. Travis, Esquire. 3. An Order in the form as attached was agreed upon by the parties. ~qlunnJ Date l Melissa eel Greevy, Esquire Custody Conciliator