HomeMy WebLinkAbout00-05985
~.- ,; '" "_,^,,"_" ~'. _.'.... ~."'" ',". c , _
f
DAVID L. DUGAN,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
DEBORAH L. DUGAN,
DEFENDANT
~s-
00-0::109 CIVIL TERM
AND NOW, this
ORDER OF COURT
..~&l
day of August, 2000, based on the within
petition for special relief, IT IS ORDERED:
(1) Deborah L. Dugan may not remove Cassandra J. Dugan, born
September 1,1991, Samantha M. Dugan, born May 9,1993 and Chance D. Dugan,
born March 20, 1996, from Pennsylvania, pending further order of court.
(2) No custody order is entered since the parties are still living together.
(3) The case shall not be referred to conciliation unless Deborah L. Dugan
files a petition to remove the children from Pennsylvania, or the parties become
separated.
John J. Baranski, Jr., Esquire
For Plaintiff
Deborah L. Dugan
205 Geary Street
New Cumberland, PA 17010
Court Administrator
:saa
t!.opio /'Ila1leJ
rt~30-00
IM~
..
~-~i%IIi@t...
. ,,""-l:i!r!!jj;~ll@iliW!Jl~lo/;
~-b1~!lit.-,.
.~l&g"-'.i,\t;.lfiSj' ~
_!&'ill ~";...i'ir......j.. '
lf~--"
.......,-~
01,,1 " p(J~o~o\,,( o'f,;tt
<6.... 30- c)O
"- -
-'-"---'-".',',,"
,'"
_"~,",~_",',, r. , .7 '" ~ ,,-
"".
l;lM-
'I.
-I
I
~ ~-
"
-.."0' "'-'''~O _ ,-.' ,_-~;';",;, '-",_j ','. _<_' "~-_'" .~,; -;.;,.'-; ';'_~;d&",i!&,,;':t.-,!- '_,'~"< _,_,_",:' _, Q,
DAVID L. DUGAN,
Plaintiff
: IN THE COURT OF COMMON IPLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
v.
DEBORAH L. DUGAN,
Defendant
: CIVIL ACTI~ . LAW
: NO. 00 ..5'tf CIVIL TERM
: CUSTODY
PETITION FOR SPECIAL RELIEF
NOW comes the petitioner, David L. Dugan, by his attorney, John J. Baranski, Jr.,
Esquire, and files this petition for special relief, representing as follows:
1. The petitioner is David L. Dugan, an adult individual residing at 205 Geary
Street, New Cumberland, Cumberland County, Pennsylvania 17020.
2. The respondent is Deborah L. Dugan, an adult individual residing at 205
Geary Street, New Cumberland, Cumberland County, Pennsylvania 17020.
3. The parties are the natural parents of three minor children, Cassandra M.
Dugan (age 8 months, born 9/1/91), Samantha M. Dugan, (age 6, born 5/9/93) and
Chance D. Dugan (age 4, born 3/20/96).
4. The children have resided with petitioner and respondent since their birth
until the present.
',-
'j,"J.o
~~c. ,,_-;
,~~. ,',4 '. "' ,",---;' .'~ --4-
5. The parties have been married to each other since November 21, 1990.
6. Petitioner believes and therefore avers that respondent intends and has
made firm arrangements to move to Minnesota on or about September 1, 2000, taking
with her Samantha, Cassandra and Chance.
7. Respondent has no family contacts in Minnesota nor does she have any present
employment opportunities there to the knowledge of petitioner.
8. Petitioner believes and therefore avers that this move is being made for
respondent's purely personal motives, not the least of which is to intentionally remove
Samantha, Cassandra and Chance from any continuous contact with the petitioner, and is
not in the best interests and permanent welfare of the children for the following additional
reasons:
A. Said move will further divide and render virtually impossible the
development of relationships and contact between Samantha, Cassandra and Chance
and the petitioner, which relationships and contacts petitioner believes are in the best
interest of the children to foster.
B. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and both sets of grandparents, which relationships
and contacts petitioner believes are in the best interest ofothe children to foster.
. "--'''-0' ' ',_,'" '.. "_1._'_:<
_~,. ,~'.'-' ",;;.-, - :~,-~. iA.';-"J' ,,,: .
C. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and all of their friends with whom they have grown up
and associated throughout their life, which relationships and contacts petitioner believes
are in the best interest of the children to foster.
D. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and their church, which relationship and contact
petitioner believes are in the best interest of the children to foster.
E. Further, said move is not in the best interests and permanent welfare of
the children for reasons which will become apparent at the time of the conciliation
conference or hearing in this matter.
9. Petitioner believes and therefore avers that the best interests and permanent
welfare of the children now require that the parties have joint legal custody of the children,
but that petitioner, have primary physical custody of all three children, subject to
respondent's rights of partial custody during specified periods as can be determined at the
time of the conciliation conference or hearing in this matter.
10. Petitioner believes and therefore avers that respondent intends to move to
Minnesota on or about September 1, 2000, and that she intends to do so with the minor
children, with or without the consent of petitioner and without seeking permission of this
Court.
11. Petitioner knows of no other party interested in this proceeding, which has
not been named in the petition and received notice thereof.
. " ~
- -><'- <(/-.-,.
, ~' ~. '-" " ~,--, ,,~+ ;,: "'",1"
...ei
WHEREFORE, petitioner respectfully requests that the parties be awarded joint legal
cLlstody of the children, but that primary physical custody of all three minor children be
awarded to petitioner, subject to specified periods of partial custody in respondent. In
addition, petitioner requests an order preventing respondent from removing the minor
children from this jurisdiction pending further disposition in this matter.
AUgust)l, 2000
J N J. BARANSKI, JR.,ESQUIRE
Attorney for Petitioner
35 East High Street, Suite 202
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court ID No. 82585
" ,--~'
'~-.-'-,", "",' -<~ ;;-,_;__ l'._
-- - ,~~', ,-,,'-"'---'-"-"-..i .;d. ---- '. 'C.'-'
.i,;
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4404, relating to unsworn falsification to authorities.
August 28, 2000
a~JZ
David L. Dug n ~
. =-.' ~-~.'''-,~'''^ -,
".-'
',".,., "
~'.
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of Petitioner, David L. Dugan's Petition
for Special Relief on the Respondent, by placing same in the United States mail at
Carlisle, Pennsylvania, Regular Mail on this 29th day of August, 2000 and addressed
as follows:
Deborah L. Dugan
205 Geary Street
New Cumberland, PA 17020
Jo J. Baranski, Jr., Esquire
Attorney I.D. # 82585
35 East High Street, Suite 202
Carlisle, PA 17013
--,.,"
. ., ," ''''''-~
c_~,
~
I
I
I
~
I
I
I
'I'
I
!
"
c' {--,
..,
~~~-; c~-'
-:J T;n>
~ r ',;-J ~}
~.'-) ::::=:
0~ (=:, :"0: i.::
..~I ,L,
Y "_:-::\ ,-,
::->. ,.,
j; ---\"1
Z (. , ::1: ~; <:)
? Cl ,-0 (j en
c:
Z -,
:<. :J'1 ~
,- ::<.
-
.L
- ~' -
. -J' k. ~.
~ :i!N"
DAVID 1. DUGAN
PLAINTIFF
v.
DEBORAH 1. DUGAN
DEFENDANT
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-5985 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this 11th day of September ,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 10th day of October ,2000, at 11:00 a.m.
for a ~e-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 TIlE COURT,
By: Isl
Me . sa P. Greev
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 ~rrangements 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 ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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
~.- ,. " - "
--~ ~-"
- -~ ..
~
,. .
/...,
..iU,
,.'
: -:.( f:t!
C). r. :
oJ'll:
CLh\{jt.::':::i ,', ,.
P;:-"'i'~I,_:J I'
__lvl\01'L 1,U,I'f!J\
,'t'-'\'J,"'\
f/Ja?M~~Z ti1f /!J~~
~./J -61<f/ 71~ ~ ;? ~ff
1'<I3-~t? tnt~ ~~~
Ii
t
Ii
Ii
1\
.,.
ii
I'.'.::
'I
,I
I:!I
i1
j1
,I
II,
i'i.1
iil
Ii]
Ii,
i!
11'1
111
'''',I.
i!~
11'.,'1
i1'
"..,1.....1.
ii'
Ii'
if.
i1'J
_ [L ~,~,~" " "-" ",..
',F'~~"'~~'
,,"T';1'~!~~MI!~I~"'I$~~~~'f~Mro ~~
--r ~ - -""."
~, -~" -",' ',. --
.'~;"'_',-k_,_;..._,~;",;i,;", ',L",,;;._-.:. _:" _', _ ."___","- > w" _;;.,')'1.
"'~, " - -~'~",,, '- ,,-<-
DAVID L. DUGAN,
Plaintiff
: IN THE COURT OF COMMON IPLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
.
.
DEBORAH L. DUGAN,
Defendant
: CIVIL ACTION. LAW
: NO. 00 -m5CIVIL TERM
: CUSTODY
ORDER OF COURT
-
NOW, this day of , in consideration of the attached Petition, it is hereby
directed that the parties and their respective counsel appear before , Esquire,
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.
Failure to appear at this conference may provide grounds for entry of a temporary or
permanent order.
By 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
,. . -"-'. ',-' -."-~'- ~ ,.,-'i.'''-- -,2,.",
~" '"
+,.'.,;>.-.' ''',~ -':.:-,:, --; --
i~
DAVID L. DUGAN,
Plaintiff
: IN THE COURT OF COMMON IPLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
v.
DEBORAH L. DUGAN,
Defendant
: CIVIL ACTION - LAW
: NO. 00 - !j"t15i:IVIL TERM
: CUSTODY
PETITION FOR CUSTODY
NOW, comes the petitioner, David L. Dugan, by his attorney, John J. Baranski, Jr.,
Esquire, and presents the following petition for custody, representing as follows:
1. The petitioner is David L. Dugan. an adult individual residing at 205 Geary
Street, New Cumberland, Cumberland County, Pennsylvania 17020.
2. The respondent is Deborah L. Dugan, an adult individual residing at 205
Geary Street, New Cumberland, Cumberland County, Pennsylvania 17020.
3. The parties are the natural parents of three minor children, Cassandra M.
Dugan (age 8 months, born 9/1/91), Samantha M. Dugan, (age 6, born 5/9/93) and
Chance D. Dugan (age 4, born 3/20/96).
4. The children have resided with petitioner and respondent since their birth
until the present.
>" ?-- -- "~ ~-'
. ,,- ., "",1 _",,__,y.,.--,~,,-,'~'_ ~.
-~iis\f
5. The parties have been married to each other since November 21, 1990.
6. Petitioner believes and therefore avers that respondent intends and has
made firm arrangements to move to Minnesota on or about September 1, 2000, taking
with her Samantha, Cassandra and Chance.
7. Respondent has no family contacts in Minnesota nor does she have any present
employment opportunities there to the knowledge of petitioner.
8. Petitioner believes and therefore avers that this move is being made for
respondent's purely personal motives, not the least of which is to intentionally remove
Samantha, Cassandra and Chance from any continuous contact with the petitioner, and is
not in the best interests and permanent welfare of the children for the following additional
reasons:
A. Said move will further divide and render virtually impossible the
development of relationships and contact between Samantha, Cassandra and Chance
and the petitioner, which relationships and contacts petitioner believes are in the best
interest of the children to foster.
B. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and both sets of grandparents, which relationships
and contacts petitioner believes are in the best interest of the children to foster.
~. .' -," ..-,.,,~. ~", '
. ~-,
',""--''-I.,''--~:.'''' -:_-,-.,-,.>-,~;; ',-~<,,-,-~ -,. jl:&~,
C. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and all of their friends with whom they have grown up
and associated throughout their life, which relationships and contacts petitioner believes
are in the best interest of the children to foster.
D. Said move will effectively eliminate any relationship and contact between
Samantha, Cassandra and Chance and their church, which relationship and contact
petitioner believes are in the best interest of the children to foster.
E. Further, said move is not in the best interests and permanent welfare of
the children for reasons which will become apparent at the time of the conciliation
conference or hearing in this matter.
9. Petitioner believes and therefore avers that the best interests and permanent
welfare of the children now require that the parties have joint legal custody of the children,
but that petitioner, have primary physical custody of all three children, subject to
respondent's rights of partial custody during specified periods as can be determined at the
time of the conciliation conference or hearing in this matter.
10. Petitioner believes and therefore avers that respondent intends to move to
Minnesota on or about September 1, 2000, and that she intends to do so with the minor
children, with or without the consent of petitioner and without seeking permission of this
Court.
11. Petitioner knows of no other party interested in this proceeding, which has
not been named in the petition and received notice thereof.
- '_ __ ~, . . ,""~" -,,'_c
'"-It.~-,;,i>.'f"-~-''''''''''''' ,"
'_r."_
WHEREFORE, petitioner respectfully requests that the parties be awarded joint legal
custody of the childten, but that primary physical custody of all three minor children be
awarded tv petitioner, subject to specified periods of partial custody in respondent. In
addition, petitioner requests an order preventing respondent from removing the minor
children from this jurisdiction pending further disposition in this matter.
Augus~ 2000
JOHN J. BARANSKI, JR., ESQUIRE
Attorney for Petitioner
35 East High Street, Suite 202
Carlisle, Pennsylvania 17013
(717) 243.6090
Supreme Court 1.0. No. 82585
~ ,." ,'-'.,,-- ,"-
. : '" . -:,". k ~ ,,'" .n" ._ " " _.
lMc
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4404, relating to unsworn falsification to authorities.
August 28, 2000
4,d!2-
david L. gan ~
~,
. - ~'"
_ -",-,",-", ~ ,-,,-".1;<: ,"_V--- _w:='
-fe,
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of Petitioner, David L. Dugan's Petition
for Custody on the Respondent, by placing same in the United States mail at Carlisle,
Pennsylvania, Regular Mail on this 29th day of August, 2000 and addressed as follows:
Deborah L. Dugan
205 Geary Street
New Cumberland, PA 17020
John . Baranski, Jr., Esquire
Attorney I.D. # 82585
35 East High Street, Suite 202
Carlisle, PA 17013
~ 0
~
<s
0 ~
,.c t
,.0
0
~\
'al
~
~
:t::
i>
D
~-
VI
\;-l
~
:)
..c.
U',V)
, "
& (J
~~
;;;- J-
'"C
14
-0(":,
rnn:
~;::
r2 ~-,~_~
r'-...--,
_~o
1;: ,-_,
,,,,(,
.Pc:
:z:
-I
-<
o
s:;
:;:..
.b
L-'
~-~
:.;")
'.J
C'
.,
""-~
'.f?
[~~i
=<
:J1
(...J
"
~~,~~
.-,
OCT 25 ZO~
DAVID l. DUGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5985
vs.
DEBORAH l. DUGAN,
Defendant
CIVIL ACTION - LAW
CUSTODY
AND NOW, this
ORDER OF COURT
/~ dayof ~r-
, 2000, in light of Judge
Bayley's Order of August 30, 2000, the Custody Conciliator relinquishes jurisdiction of the
above-docketed matter.
IO//57~~
Date
Melissa e Greevy, Esquire
Custody Conciliator
,
F1L~D-OlT1CE
0- -, ". ~~-'-, '.-.1 ")-'RY
1_ 1 i-"~ ,-" !.,: ,--', ): ,..; ,'\ _! I >'-It-'
t " _ , - _'~" __, " "u \
00 NOIJ -8 Ai'! 10: 48
CUMBtl-ll./'ND COUNW
PENNSYLIh'lNIA
[i
II
!:l
-, ..
[m~
.""-
WI}~~~~\'~I' '. ,_ _ ~<.
roe""..
, C' ,~,p~:'l~,~
'-, ,.. .; ~ '. "" - 'he-,- __, - ,,- ,,, " - ~"-,".-, -".,'_, - ~; ".'*"--~__' ~ ,'..,~",;~,.,." '_" __
'.
DAVID L. DUGAN,
Plaintiff
: IN THE COURT OF COMMON IPLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
v.
DEBORAH L. DUGAN,
Defendant
: CIVIL ACTION - LAW
: NO. 00 . CIVIL TERM
598"5
: CUSTODY
.
.
ORDER OF COURT
NOW, this ---!O- day of f\.lCIAt, 2001 on petition of David L. Dugan, and on
motion of John J. Baranski, Jr., Esquire, it is hereby Ordered and Directed that:
1) Defendant Deborah L. Dugan is hereby adjudged and decreed to be in
contempt of court for direct violation of the this Court's August 30, 2000 Order.
2) Defendant Deborah L. Dugan is ordered to return to Cumberland County
immediately with the parties' minor children, Cassandra M. Dugan, Samantha M. Dugan
and Chance D. Dugan.
3) Pending further order of court, primary physical custody of the parties' minor
children is granted to petitioner, David L. Dugan.
Coj;)'t 'jt'vtU -10 ~~fcc'
J\.b.lu:e.- ~LLu.c -10 ~
S/Io/O/ ~
<~,.
~
, ,.'. ~ ~" . "..~ " 0 <'0 - 1
..~ "'~~
OJ' - .::i'U<)TARY
[II "n' I f) pi" L' 21
filrJ, I, ,I 4 .
CUtvii3l:iiuliji) COUN1Y
PENNSYLVANiA
,~ .~
m~
,',^
'," ---~ "~",,,,'~'-" .
",
DAVID L. DUGAN,
Plaintiff
: IN THE COURT OF COMMON IPLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
v.
DEBORAH L. DUGAN,
Defendant
: CIVIL ACTION. LAW
: NO. 00 - 5989 CIVIL TERM
: CUSTODY
PETITION FOR ORDER OF CONTEMPT AND FOR
EMERGENCY CUSTODY
NOW, comes the petitioner, David L. Dugan, by his attorney, John J. Baranski, Jr.,
Esquire, and presents the following petition for an order finding the defendant Deborah L.
Dugan in contempt and awarding primary physical custody of the parties three minor
children to petitioner and in support thereof, represents as follows:
1. The petitioner is David L. Dugan, an adult individual residing at 205 Geary
Street, New Cumberland, Cumberland County, Pennsylvania 17070.
2. The defendant is Deborah L. Dugan, an adult individual who resided at 205
Geary Street, New Cumberland, Cumberland County, Pennsylvania 17070 until Friday,
May 5, 2001.
3. The parties are the natural parents of three minor children, Cassandra M.
Dugan (born 9/1/91), Samantha M. Dugan, (born 5/9/93) and Chance D. Dugan (born
3/20/96).
,__ C~ __,~ _
,'," ~~..-
-;1
4. On petition of the petitioner, this Honorable Court entered an Order dated
August 30, 2000, directing defendant not to remove the children from Pennsylvania
without further order of Court. A copy of the Order is attached hereto as Exhibit "A".
5. Petitioner believes and therefore avers that on May 4, 2001, defendant
removed the children from Hillside Elementary in New Cumberland, Pennsylvania and left
Pennsylvania with the intent not to return, in direct violation of this Court's August 30, 2000
order.
6. Petitioner believes further that defendant is currently residing with the
parties minor children in the home of Brian Wussaw at 34 Summit Park, St. Peter,
Minnesota, 56082 and has registered the children to attend South Elementary School in
S1. Peter, Minnesota.
7. Jurisdiction ofthis matter is proper in Cumberland County, Pennsylvania as
both parties and the children resided in Cumberland County until May 5, 2001 and
defendant has not established residency for herself or the children in Minnesota.
WHEREFORE, petitioner requests an Order of Court holding the defendant in
contempt and directing the immediate return of the children to Cumberland County,
Pennsylvania. Further, petitioner respectfully requests an emergency order awarding the
petitioner primary physical custody of all three minor children pending a hearing on the
~ =~
- , ~-..' '2.____ '"~~_r.~._.",;&.;a~C>o._,_,,'"
~T-'n
.
issue of contempt or a Conciliation Conference with the Cumberland County Custody
Conciliator.
May 10, 2001
JOHN J. BARANSKI, JR., ESQUIRE
Supreme Court I.D. No. 82585
35 East High Street, Suite 201
Carlisle, Pennsylvania 17013
(717) 243-6090
Attorney for Petitioner
-- - ~ ~ - ,~-_~" -,,~.-. ..-"""-Y^';~~'C= ",__e_"" '._c_ ~_ _ ,_
.
VERIFICATION
I do hereby verify that the facts set forth in this petition are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4404, relating to unsworn falsification to authorities.
May 10, 2001
a~~ ~
David L. Dugan ~
'-">-;';".- ."
~ . ".'<l'e" 1.,,',,- '. ",,'" , - ,-- -- ,
. "II.. ",,," -,,,'" -,;.'- ':, ''-~ ',; _','__.-,\l--'_-'C, .-';,'.' :"'.,,~=" ;--i-,~_ 'J-',
i'_
DAVID L. DUGAN,
PLAINTIFF
V.
DEBORAH L. DUGAN,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
'.
AND NOW, this
: 00-5989 CIVIL TERM
ORDER OF COURT
,qr.&i
"";"V day of August, 2000, based on the within
petition for special relief, IT IS ORDERED:
(1) Deborah L. Dugan may not remove Cassandra J. Dugan, born
September 1,1991, Samantha M. Dugan, born May 9,1993 and Chance D. Dugan,
born March 20, 1996, from Pennsylvania, pending further order of court.
(2) No custody order is entered since the parties are still living together.
(3) The case shall not be referred to conciliation unless Deborah L. Dugan
files a petition to remove the children from Pennsylvania, or the parties become
separated.
John J. Baranski, Jr., Esquire
For Plaintiff
Deborah L. Dugan
205 Geary Street
New Cumberland, PA 17010
:saa
-
Court Administrator
C"I.Htl;''l HA It
C', ~__ ~
, .'.'.' a-...__~ ...
! ,. ,\ ""-IUlIIWIUIiII ,I
'" ,'\;:,:.::<. ~ '
";'J,.;" ."..' .'
~--<"'-_" "; '" ,'" -~,', J<
!if;
" ~ .-,
<0--"--"; -,,-,,,,-,,
'I- \ <l ".,
,..;;- ~ '~'~'< "-"-~"
.
.
--- ,.;"'
~'"
~~fV
:fl
0-
~
~
'-^
o
C
-0 tl~,
rnf!~
-:<>- '-',
~~
~~~
r::Ej
>C'
-7 -
~8
:z:
=<
co
,.r'~1
~l
~
,:-;;
~
, .
o
'"~A 'c:;
~~~ ~~~
~:;2(~
(::srn
--;
~
--a
~
c,.::
~
U1